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OAR Box 1875 

Prepped by Ollie Stewart 

Document Number: 

36) ll-E-54 

Docket Number: 

A-90-19 

Printed 12/1/200811:12:46 AM Sheet 36 of 86 
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* 9. A-90-19 

%}>JoO. - \x ll-E-54 

MEMORANDUM ';' . Q£Q I 8 1992 

i , 

DATE: August 20 , 1992 w „ ' -

. 4 •' 

SUBJECT: Teleconference with CMA on HON Monitoring, Reporting, 

and Recordkeeping Requirements 

On August 20, 1992, representatives of the Chemical 

Manufacturers Association (CMA) and the Environmental Protection 

Agency (EPA) participated in a teleconference to discuss the 

monitoring, reporting, and recordkeeping requirements in the 

draft proposed hazardous organic national emission standards for 

hazardous air pollutants (NESHAP), commonly known as the HON. A 

list of participants is provide in Attachment A. The agenda for 

the meeting is provided in Attachment B. 

During the meeting, the participants discussed the status of 

issues outlined by CMA in two handouts from the July 17, 1992 

CMA/EPA meeting (Attachments C and D) as well as a document CMA 

telefaxed the EPA on July 30, 1992 (Attachment E). 

The following topics were discussed during the 

teleconference: 

1. Issue: What length of time should a source be required to 

keep records? 

Outcome: Records must be kept for 5 years. The EPA is 

reviewing what data should be kept. 

2. Issue: What should be the' trigger for quarterly reporting 

within the incentive system? 

Outcome: Deviations (from the HON parameter ranges) for 

more than 1 percent of the operating time or monitoring downtime 

that exceeds 5 percent of the reporting period, followed by a 

request from the delegated authority. 

3. Issue: What types of documentation for TRE calculations, 

performance tests, and design specifications should be kept and 

how much of this should be reported. 
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Outcome: Provide in the report full documentation of one of 

each type of action undertaken and only the results for each 

additional action of the same type. 

4. Issue: Is it necessary to submit a storage maintenance 

plan? 

Outcome: A storage maintenance plan is not required. Each 

periodic report must include the actions the owner or operator 

anticipates will be taken during the next 6 months in order to 

maintain the closed vent system control device. 

5. Issue: When checking seals on diversions for process vents, 

what information must be included in the report? 

Outcome: A report of any diversions or damaged seals is 

sufficient. 

6. Issue: Is it necessary to have a shorter monitoring 

interval for short transfer loading cycles? 

Outcome: The EPA will review this after proposal. 

7. Issue: Can the Reportable Quantities (RQ) system be 

substituted for spot report submittals? 

Outcome: The EPA may seek comment on this issue in the 

preamble and will review this after proposal. 

8. Issue: What criteria and system should be used if delegated 

authorities approve alternative monitoring requirements? 

Outcome: A system similar to that in §63.8(e) of General 

Provisions [overriding (3)(i), (3)(ii), and (3)(iii)] including a 

description of the parameters and anticipated range of values, 

and a performance test once controls are in place. 

9. Wrap-Up: The commitments made by each group were reviewed. 

It was agreed that the EPA and CMA should meet again to discuss 

the implications of the requirement for keeping "support data" in 

the Operating Permits rule [CFR Part 70.6(a)(3)(ii)(B)] and how 

that requirement would be interpreted for the HON. The next 

teleconference was set for September 15, 1992, from 2-5 pm. 
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ATTACHMENT A 
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CMA/EPA TELECONFERENCE 

August 20, 1992 

Participant List 

Name 

Amy Meyers 

Gary O'Dea 

John Dege 

Rick Phelps 

Linda Herring 

Daphne McMurrer 

Jan Meyer 

Charlie Garlow 

Jane Engert 

Scott Throwe 

Brian Taranto 

Valerie Everette 

Joe Hovious 

Affiliation 

CMA 

CMA 

DuPont 

Eastman Kodak 

EPA, ESD 

EPA, ESD 

EPA, ESD 

EPA, OE 

EPA, SSCD 

EPA, SSCD 

Exxon Chemical 

Radian Corporation 

Union Carbide 
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ATTACHMENT B 
P.7 

CMA/EPA TELECONFERENCE 

August 20, 1992 

Meeting Agenda 

2:00-2:30 Summary of the Issues 

2:30 - 3:15 Storage of Records 

3:15 - 3:30 Incentive Trigger 

3:30 - 3:45 Documentation 

3:45 - 4:00 Storage Maintenance Plan 

4:00 - 4:15 Process Vents/Seals on Diversions 

4:15-4:30 Reportable Quantities (RQ) System 

4:30 - 5:00 Wrap-Up 
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ATTACHMENT C 
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£_ 

:HEVIICAI_ MANUFACTURERS ASSOCIATION 

CMA ALTERNATES TO REDUCE MONITORING, RECORDKEEPING, AND REPORTING 

BURDENS WITHOUT SACRIFICING COMPLIANCE DATA 

A. HON and preamble allow sources to propose alternative monitoring, 

reporting, and recordkeeping systems and for these to be easily 

approved by permitting agency. 

B. Clarify monitoring, recordkeeping, and reporting requirements 

between overlapping or conflicting Subparts 

1. Clearly state all monitoring, recordkeeping 

and reporting requirements that impact HON 

sources in the HON and clearly specify in 

the HON which items in General Provisions, 

Enhanced Monitoring, etc. do not apply 

Example 63.103(a)(1) 

Greatly simplified 

compliance, better 

understanding for 

regulated community 

Greatly simplified 

compliance 

2. Separate monitoring, recordkeeping, and 

reporting provisions in HON according to 

type of control device rather than type of 

emission point. For example, put all items 

covering flares in one place, all on incinerators 

in one place, etc. 

C. Minimize recordkeeping and reporting requirements as follows 

1. One semiannual report of all deviations 

(including Subpart H) included in report at 

times to be selected by permit holder. All 

other required reports would be included in 

the semiannual report. 

2. Keep records of applicable data, defined as 

periods of deviations, plus periods when 

monitoring systems are not working. 

Reporting is 

simpler, burden 

reduced 50+% 

Reduces recordkeeping burden 

by 90+% 

3. Disincentives for poor performance, i.e., if 

number of exceptions is excessive, require all 

records for that control or monitor to be retained 

for one year. 

Do not submit reports on design, initial 

performance tests, or similar items not 

related to routine performance. Keep data 

on site for inspection on demand. 

Number of reports 

greatly reduced 

2501 M Street. NW. Washington. DC 20037 202-887-1100 Panafax 202-887-1237 Telex 89617 (CMA WSH) 
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D. Minimize unnecessary performance tests and continuing monitoring 

requirements 

1. Do not require performance tests or ongoing 

monitoring where acceptable data such as 

design calculations, engineering data or 

material balances would indicate low 

probability of Group 2 sources actually being 

Group 1 sources. 

Significantly 

reduces Group 2 

monitoring 

Do not require multiple monitoring requirements for multiple entry points to a control 

device. Sample and monitor aggregate entry 

stream only. 

Provides compliance 

data with greatly 

reduced monitoring 

needs 
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ATTACHMENT D 
P.12 

C^AF T 

Details: Ref: EPA Summary 

Storaqe Tanks 

63.120 (d) 

2&3 

122 (a-d) 

124 (e) (3) 

123 (a-c) 

0 

0 

0 

0 

0 

Process Vents 

117(a) 

117(a) 

117(C) 

0 

0 

0 

Operating plan Ok 

Maintenance plan unnecessary 

Describing controls in an initial report is redundant since it 

will be required in the compliance plan and in permit. 

Maintenance plan superfluous along with record of 

maintenance activities 

(Inspections) - should be a report and should be included in 

6 month report. 

(compliance method) delete; included in permit 

conduct performance test -add "where appropriate" 

initial report w/schematic - delete since this will be part of 

permit submitted 

117(d) Revise to "alternate compliance plan can be submitted to 

Administrator for approval" 

117(b) Performance test as appropriate - redundant since it will be 

part of permit 

117(b) 

117(b)(IV) o 

No initial report of performance test should be required. 

Records should be maintained. If report is mandated, should 

have 90-180 days to report. 

TRE records requirement should add "operating parameters" 

or calculations" 
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•% 4 > I 

117(b)(IV) 

117(b)(v) 

118(a) 

118(d) 

118(d) &(e) 

11.8(c) 

118(d)(5) 

Transfer 

129(d) 

130(e)(f) 

129 (a) 

fuel 

129(a)(7) 

129(a) 

129(b) 

130(a) 

130(b) 

130(d) 

jad0713c 

i 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

0 

"bft-A^T" 

No report of TRE should be required. Records would be 

available 

Record only TRE calculation data 

For seals on diversion, record date inspected and any 

deviations. 

Change "exceedance" to deviation; include deviations in 

six month report 

Deviations would be in six month report 

TRE calculation is being addressed 

TRE code should be recorded only. 

Revise to maintain up-to-date description of vent system 

delete - DOT regs apply 

delete "duration of loading cycle" - Performance test should 

be representative of loading conditions. 

Should only maintain up-to-date records. Include primary 

exemption 

Keep up-to-date records only 

Keep performance test records only 

Performance tests records only 

Same as process vents 

Include deviations in six month report 

Include deviations in six month report 
•« «.• I 

ATTACHMENT E 
" P.15 

* * 'yUL-30-1992 15:36 FROM CHEM. MANUFACTURERS ASSN. TO 919195414028 P.02 

CHEMICAL MANUFACTUR£RS>^SSOCIATION 

HON REPORTING BfiQUIRtMENTS 

I. Two-Tiered Reporting Systea 

In the HON, EPA requires that facilities monitor a Significant 

number of quality parameters and report periods when the monitored 

parameters are outside of specified boundaries. However, changes in 

monitored parameters outside specified ranges (MPCs) do not show that a 

control device is operating outside the prescribed efficiency level. 

For instance, a combustion device may operate outside the required 

temperature range, but still maintain a 98% control efficiency. 

Honitored parameter changes (MPCs) are merely indicators: that a device 

may not be operating at a specified efficiency. 

CMA proposes that EPA adopt a two-tiered ^pproaclf: to recordkeeping 

and reporting under the HON: significant events would bfc reported 

promptly, while all MPC data outside of specified ranges would be 

reported semiannually. We believe our approach encourages meaningful 

analysis of data relevant to a source's compliance status. 

Facilities and permitting authorities should not:be Overburdened 

by prompt reporting of all HPC's. Facilities and permitting 

authorities would be forced to spend excessive man-hours compiling and 

reviewing insignificant data* 

The proposal listed below ensures that every deviation from a 

specified parameter, as reflected in an MPC, Will come to the attention 

of the permitting authority. Our proposal also allows, facilities and 

permitting authorities to focus their immediate attention on important 

occurrences. 

A. Semiannual Reporting 

CMA suggests that the HON specify that monitored parameter changes 

(MPCs) be reported semiannually. Semiannual compilations of MPCs will 

provide permitting authorities with adequate data to make informed 

decisions. More frequent submissions from all HON sources would 

inundate the system and reduce the effectiveness of the program. 

The seaiannual report would be a (comprehensive statement of 

significant events and monitored parameter changes recorded during the 

previous reporting period. The report could include an analysis of why 

an MPC does not indicate a departure from the control standard. This 

analysis would form the basis of discussions between the source and the 

permitting authority over the need for performance testing or increased 

reporting (see Reporting Incentive Program, discussed below). 

Semiannual reports mesh well with other regulatory requirements. 

They are consistent with §63.10(e)(3) of the General Provisions which 

requires semiannual "excess emissions and continuous monitoring system 

performance" reports. Semiannual reports are also consistent with the 

provisions of the operating permit rule, §70-6(a)(3)(iii)(A). 

2501 M Street. NW. Washington. DC 20037 202-867-1100 fianafax 202-837-1237 'Telex89617 (CMA WSH) 
• — p 1fi 

'* ?UL-30-1992 15=37 FROM CHEM. MANUFACTURERS ASSN. TO • 9l9i954i4Q28 P.03 

B. Significant Events 

Truly significant events need to be promptly reported to the 

permitting authority. Prompt reporting should be limited to those 

situations where monitoring ox control equipment either severely 

malfunctions or shuts down. We believe that this would allow sources 

and permitting authorities to concentrate their scarce resources on 

truly significant events. 

Existing reporting requirements already encompass the types of 

events that should be promptly reported under the HON. Under the 

CERCLA Reportable Quantities program (RQ), statistically significant 

increases of HAP emissions beyond permitted levels are immediately 

reported to the National Response Center, 40 C.F.R. §302.8. All HAP 

materials are included at reporting trigger levels. The types of 

events that trigger an RQ report include the equipment malfunctions and 

shutdowns that should be promptly reported under the HON. Sources 

already have the reporting systems in place and regulators have the 

systems to receive these reports. 

EPA should regard the CERCLA RQ reports for HAPs As sufficient to 

satisfy the prompt reporting needs of the HON. This approach avoids 

duplicity and encompasses all significant events that ought to come to 

•the immediate attention of the permitting authority. Every other 

deviation, as reflected in the MPC report, would be reviewed 

semiannually. 

It. Reporting Incentive Program 

The HON reporting system' should encourage facilities to 

consistently operate their control devices within the specified 

parameter ranges. CMA recommends an incentive program! which would 

place marginal performers into a quarterly reporting frequency and/or 

require them to maintain more records on specific emission points, and 

put them back into semiannual reporting once they demonstrate 

consistent operation within the specified parametersA facility should be considered for increased reporting duties 

based on the extent of MPCs contained in the semiannual report. The 

exact level of MPC could be defined in terms of percentage - CMA does 

not propose an exact threshold at this time. Once a facility exceeds 

the threshold, discussions with the permitting authority would ensue 

over whether increased reporting is merited. At this point, the 

facility would have the opportunity to show, through performance tests 

or other means, that Increased reporting is not warranted. 

If the permitting authority determines that increased reports 

should be required, the facility would submit quarterly reports for one 

year. If the reports show that the facility operated; below the defined 

MPC threshold for the year, the facility would automatically revert to 

semiannual reporting. If the reports show that the facility exceeded 

the threshold, quarterly reporting would continue until the facility 

shows one continuous year of operation below the specified MPC level. 

TOTAL P.0: