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OAR Box 1669 

Prepped by Charmelle Mathews 

DocumeytNumber: 

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Docket Number: 

A-98-13 

Printed 9/23/2008 9:36:49 AM Sheet 70 of 110 
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MEMORANDUM 

TO: Steve Shedd 

U.S. EPA, OAQPS/ESD/WCPG 

FROM: Greg LaFlam^££ 

Pacific Environmental Services, Inc. (PES) 

DATE: February 2, 1998 

P:\N812 

SUBJECT: Telephone Call with the American Petroleum Institute -

Orgamc Liquids Distribution (non-Gasoline) NESHAP 

PARTICIPANTS: Bill Beck 

Chuck Feerick 

Jay Helms 

Bob Hermanson 

Greg LaFlam 

Denise Michelson 

Janet Peargin 

Mark Pike 

Karin Ritter 

Steve Shedd 

Gary Wilson 

Mobil Corporation 

Exxon 

PES 

Amoco 

PES 

ARCO Pipe Line 

Chevron 

Exxon 

API 

U.S. EPA 

Marathon Oil 

(703) 849-6295 

(713) 656-6594 

(919)941-0333 

(312)616-0529 

(919)941-0333 

(562) 428-9449 

(415)894-8468 

(713) 656-6594 

(202) 682-8472 

(919)541-5397 

(419)421-4299 

The EPA participated in a conference call with the American Petroleum Institute (API) 

on January 16, 1998 from 11:00 am to noon. The purpose was to discuss API's comments on 

the draft industry survey for this category that the EPA had distributed for review in December 

1997. The issues raised by API, and the ensuing discussion, are summarized below. 
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Memo to Steve Shedd 

February 2,1998 

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Summary of API's Comments on the Draft Survey 

A. Provide clarification of source category definition. 

1. What is meant by a "terminal"? 

2. What is an "organic liquid"? 

- do they need to contain HAP (volatile HAP)? 

- many materials contain very small HAP amounts, and/or HAP that do not 

volatilize; it may be unreasonable to regulate these 

Discussion 

API: Perhaps the EPA should exclude some liquids that have low or nonvolatile HAP 

contents (lube oil, asphalts, etc.). Total vapor pressure or HAP partial pressure could serve as 

one potential cutoff parameter. 

EPA: We need to obtain HAP contents of these types of liquids before such exclusions 

could be justified. 

API: HAP data ofthis type are not generally available, but companies could make 

estimates. A matrix table could be constructed, with boxes for low, medium, and high HAP 

content and vapor pressure. A proprietary study to obtain this information has been conducted 

by industry, but the data are presently restricted to the study participants. The API said they 

would see if those data could be made available. 

B. Two industry suggestions: 

1. Exclude operations (including storage, transfer, wastewater, non-aqueous waste, and 

equipment leaks) that are already subject to another MACT rule. 

2. Exclude facilities that emit actual emissions less than 50 percent ofthe major source 

HAP levels. 

Discussion 

EPA: We are reviewing the existing, related MACT rules to determine whether any 

emission sources remain unregulated. We solicit industry input to understand the extent of • 

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Memo to Steve Shedd 

February 2,1998 

Page 3 

coverage. Survey needs to ask HAP contents and what all the operations at the facility are. 

API: Much ofthe requested infonnation will probably be unknown, especially certain 

HAP contents and detailed wastewater data. 

C. Other matters 

The API representatives indicated that Word® software best suits their uses, ifthe 

survey is transmitted in electronic fonnat. One company indicated that the amount of 

information requested in the draft survey seemed somewhat overwhelming. The EPA requested 

that the companies have a terminal person review the survey to check its reasonableness. 

Following the EPA's Roundtable meeting set for January 21,1998, and a review ofthe 

EPA/API discussion of January 16th, industry will provide additional comments on the draft 

survey. The EPA will provide hard copies ofthe survey at the Roundtable and will discuss 

some of these issues further at that time.