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OAR Box 1875 

Prepped by Ollie Stewart 

Document Number: 

47) ll-E-65 

Docket Number: 

A-90-19 

Printed 12/1/2008 11:12:47AM Sheet 47 of 86 
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A-90-19 

ll-E-65 

SUMMARY OF TELECONFERENCE 

Date: October 6, 1992 

Subject: Chemical Manufacturers Association Monitoring and 

'Recordkeeping Issues on the Hazardous Organic NESHAP (HON) 

Attendees: Lydia Wegman, Deputy Director of the Office of Air 

Quality Planning and Standards, EPA 

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, 

EPA 

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 are three documents discussed at this meeting. The 

first is a note from Daphne McMurrer, of EPA, to Annette Stanley, 

of CMA. The note includes draft preamble language on alternative 

recordkeeping requirements. At the meeting, CMA indicated that 

they had not yet had sufficient time to review the draft preamble 

language, and would need several more days to comment. There was 

no further discussion of recordkeeping at this meeting. 

The second attachment is a handout provided by CMA in response 

to a request from EPA at their September 29, 1992 meeting. This 

handout includes answers to questions EPA posed regarding 

monitoring of parameters used to gauge the operation of control 

devices. Most of the meeting was spent discussing this handout. 

Specifically, CMA explained the examples of events that would cause 

excursions beyond permitted parameter ranges included in the table 

in their handout. In addition, the group discussed some of the 

ideas in the CMA handout. Of particular interest was the idea of 

having all the monitoring results from a 24-hour period considered 

together if values beyond the permitted range were recorded. This 

would address the fact that sources cannot always take actions to 
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correct whatever condition is creating the monitoring excursion 

immediately, but would allow the source no more than 24-hours 

before another excursion was recorded. After the discussion, EPA 

agreed to prepare a draft system of compliance with the monitoring 

provisions of the HON. 

The third attachment is a calculation EPA prepared to 

illustrate the concept of allowing some "excused" periods of 

monitoring values beyond certain pre-set ranges. 

3 Attachments 
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(\tfpuoiA*.e"Jr . 

Note to Annette Stanley 

OCT « 5 1992 

From Daphne McMurrer

 v 

This is draft language that EPA is considering for inclusion 

in the HON preamble to address the CMA issue on recordkeeping with 

certain computer systems. Please get it out to your members in 

time for tomorrow's call at 10:00. I assume you will be calling in 

to Lydia Wegman's number like you did last week. If not please 

call me to talk logistics ASAP. 

HON Recordkeeping 

To be inserted into the R&R Section 

The proposed rule requires sources to keep readily accessible 

records of monitored parameters. For those control devices that 

must be monitored continuously, records must include at least one 

monitored value for every 15 minutes of operation. These 

monitoring records must be maintained for 5 years. Industry 

sources have informed EPA that some existing computer controlled 

processes have monitoring systems that only store data that is 

outside some predetermined range of acceptable values. For 

example, these systems could be set to record and store all 

monitored values outside the parameter ranges established by the 

source to represent proper operation and maintenance of a control 

device. Such a computerized system, if well designed and properly 

operated, could accurately record all values outside the 

established range. Records from such a system provide assurance to 

the source that the monitored parameters are within the permitted 
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range at any time period for which a record is not made or stored. 

At this time, EPA does not have sufficient data about these 

systems to ensure that they are accurately and reliably reflect the 

source's continued compliance. Therefore, EPA has not included 

them as a recordkeeping option in the proposed rule. Instead, EPA 

is seeking comment on whether and how these systems should be 

allowed for compliance with the recordkeeping requirements in the 

HON. Specifically, EPA is interested in: what criteria are used to 

determine the values that are stored by these existing monitoring 

systems; how the validity of the data is verified; the frequency of 

calibration for this type of system; how operators ensure the 

accuracy of the results from these existing systems; and what types 

of processes or controls are currently being monitored with these 

systems. In addition, EPA is seeking comment on how the 

requirements allowing the use of these systems to comply with the 

HON might be structured. Finally, EPA is seeking comment on the 

concept of determining compliance based on data that do not include 

values to represent the entire compliance period (i.e., absence of 

data indicating a violation would constitute evidence of 

compliance). 
PR 

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HON Compliance and Operating Parameters 

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

CMA RESPONSE: 

HON would state that compliance is generally defined as the 

installation and proper operation and maintenance of reference control 

technology (or equivalent as approved by EPA). Control device efficiencies 

are nominal, conservative numbers set to represent reasonable ranges for 

typical devices under "representative conditions" as opposed to numerical 

limits for performance. Each source should have flexibility to negotiate 

appropriate ranges for operating parameters in its permit. However, appropriate 

default ranges should be included in the rule, not in guidance. 

2) Should a number of parameters monitoring excursions be excusable? 

CMA RESPONSE: 

Yes. The preamble to the HON would state that deviation from operating 

parameters does not necessarily mean noncompliance. 

3) If so. how should the system of excusable parameter excursions be structured? 

CMA RESPONSE: 

Some number of deviations outside the normal parameter range would not 

constitute a violation. For details, see answer to question 3(c). 

Background 

EPA considering die use of parameter monitoring as an indicator of proper operation and 

maintenance and allowing some number ("x") of excursions beyond Uie 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 absorbers. 

Regarding # 2 parameter monitoring: There is some variation among the kinds of 

points, but, in general, die monitoring data are averaged over 3-hour periods. 
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CMA Addition: 

• HON is based on installation and proper operation of reference control technology. 

Specified parameters to be monitored are indicators, but not a direct measure of system 

performance. Even a well developed and operated system will not meet system 

requirements 100% of the time. For these reasons, it is important not to have each 

deviation from specified monitoring parameters be a violation. 

Ouestions 

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)?; 

CMA Response: 

Excursions happen for a number of reasons, some associated with process 

operating variables, some due to maintenance needs, some beyond the physical 

control of the source. 

- what efforts are needed to prevent excursions?; 

CMA Response: 

Some redundancy can be built in to eliminate some excursions, but generally 

this is of limited value. Where plants use computer control, some electronic 

trouble shooting before reaching set points can be used, but only if the cause 

of the excursion lends itself to quick fix. Preventive maintenance helps, 

but does not guarantee no excursions. 

- what is needed to stop on-going excursions?; 

CMA Response: 

See attached table for examples 

-how long should it take to stop an excursion? 

CMA Response: 

See attached table for examples 

b. EPA needs CMA to identify causes for excursions outside die parameter boundaries mat a 

source would set for themselves in the permit, such as: 

- operating variations? 

-control device "malfunctions" 
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-others? 

Sec attached tahle 

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 

facility-wide total waste quantity provisions 

CMA Response: 

In general, there should be virtually no monitoring requirements for Group 2 vents. 

Changes in parameters monitored on Group 2 process vents are only an indication that the 

TRE may need to be recalculated. In this case, the only violation that can occur is if the 

source fails to recalculate the TRE when monitored data indicates a need to do so. 

There should be no monitoring requirements for Group 2 points for tanks, transfer 

operations and wastewater. 

b. Should die system of excused periods be used only for continuous parameter monitoring 

provisions? 

CMA Response: 

Certainly, this most easily applies to parameter monitoring. Application to inspections or 

work practice monitoring is appropriate, but is certainly more difficult to define. We will 

continue to think about this issue and provide additional comments in the future. 

3. Number and duration of excused periods: 

a. What units of time should be used to define excused periods? 

- One 3-hour average 

- One operating day 

-Specify by point and control device used (whatever die monitoring frequency of mat 

device) 

CMA Response: 

-A 24 hour period of operation 

The HON standard should be based on a maximum of 1 exceedance per day per point. This 

means that no matter how long the exceedance may last during that day, it would trigger 

only one deviation. Excused periods should correlate with this since it may take several 

hours to achieve correction once a deviation occurs even for the simple cases. 
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b. How should the excused periods be allocated? 

per control device 

-per process unit 

-per plant 

-by number and type of control device (die item Uiat must be monitored) 

CMA Response: 

Should be determined per control device. 

Reflects that control device is basis for compliance. 

c. How can EPA determine die number of excused excursions Uiat equate to proper operation 

and maintenance? 

CMA Response: 

This should be considered as a floor question based on data from controlled sources. 

In the absence of sufficient data, CMA believes that a level of 6 deviations/reporting 

period is appropriate. Significant additional data will be available when new systems 

are on line. New data may be a basis for adjusting the numbers at that time. In 

addition, investigations of deviations (See 4A) should produce additional information. 

4. If a work practice approach to die parameter monitoring requirements is to be developed: 

a.. What are appropriate follow-up actions? 

CMA Response: 

For every initial deviation (including excused deviations) initial follow up would be 

investigation and documentation of cause and responses. For multiple deviations traced to 

the same cause, the source would have to develop and implement an corrective action plan. 

b. Should die required follow-up actions be listed specifically or generically? 

CMA Response: 

Listed generically in HON. Specifics should only be included in the corrective action plan, 

permit 

c. In what time must Uie actions be completed? 

CMA Response: 

Reasonable time as developed with permitting authority. 
Deviations: Additional Information 

Examples of Possible 

Excursion Cause(a) 

1) 

Emission Control 

Device upset 

2) 

Process Unit 

Upsel 

3) 

Statistical Variability 

4) 

Instrument 

Problems 

5) 

Control Valve 

Problems 

6) 

Extreme Envir. 

Conditions 

7) 

Catalyst 

Poi.soning 

Time of 

Excursion 

Short 

Med 

Short 

Short 

Short 

Long 

Long 

Frequency 

of occurence (b) 

Frequent* 

Frequent 

Dependent on 

set parameter 

Frequent 

Med 

Rare 

Rare 

Efforts Needed 

to prevent (c) 

or minimize 

PM 

D.PM.MO 

D 

PM.D 

PM 

PM.MO 

Corrective Action 

(d) 

M. EC. PC 

SSM 

SSM 

W 

M.EC 

M£C,SSM 

W, PC 

PS 

Length of Time 

to Stop 

Short 

Short 

Short 

Short 

Short 

Med- Long 

Med 
8) 

Off Spec. 

Fuel 

9) 

Cooling Water 

Contamination 

10) 

Vendor Error/ 

Miscalculation 

11) 

Human Error 

Med 

Med 

Long 

Short 

Med MO 

Rare 

Rare* 

Frequent 

MO 

D 

SSM 

M-W 

PC 

MO 

Short 

Med 

Long 

Short 

Time of excursion - Short = < 1 Day, Med = 1-2 Days, Long = 2 Days or More 

Frequency of occurence - Frequent = Several X/Yr, Med = IX/Yr. Rare = IX in several years 

Efforts needed to prevent or minimize/Corrective Action:- PM = Preventive Maintenance. D = Design, MO = Monitoring, M = Maintenance. PS = Process 

Shutdown & Major Maintenance, PC = Permit Change. W = Wail. EC = Equipment Change, SSM = Startup, shutdown & Malfunction Plan. T= Training 

Length of time to stop - Short = < 1 Day, Med = < 1 Week, Long =-Several Weeks or Change in Standard needed 

a) These examples are not "malfunctions" and would generally impact monitored system parameters such as temperature or flow, but would not necessarily 

result in reduction in control device performance. The intent would be to continue operation (widi corrections as necessary) rather than going through a shutdown-fix-startup cycle. 

b). Represent conditions after systems complete initial start-up and reach equilibrium operating condiUons. In cases identified by * deviations will be more 

frequent during early operation. 

c) Does not imply mat 100% prevention always is possible. 

d) Appropriate corrective actions to stop. 
Additional Information on specific examples 

1) Operating condition of emission control device which results in a deviation in monitored parameter. Deviation does not necessarily result in 

significant or long term reduction in system performance. Examples would be: 

Incinerator - mechanical or electrical component trip, thermocouple failure,. variaUon in feed from combined process streams; 

Scrubber- temporary plug flow variations 

boiler/process heater - thermocouple failure, process heat or steam requirement change, combustion air trip; 

steam stripper - flow variations, phased organics in feed, monitor failure; 

condenser - temporary fouling, flow variation, water contamination, high cooling water temperature, freezing. 

2) Examples of process unit upsets which could cause control device operating parameter variability include off specification feed, minor equipment 

problems (pump trip), raw material flow or quality changes. 

3) Systems are usually designed for certain limits of operation (95% conditions). CondiUons which fall outside diese design parameters could cause 

operaung parameter deviations. Statistical variability also covers random deviations in device parameter readings which are otherwise unexplained. 

4) Instrument problems include both a) instruments monitoring system parameters and b) instruments which control processes. Key areas are sample 

system problems such as plugging, pump failure, air line leaks, electrical problems, failure of recorders to record, etc. 

5) Control valve problems include items such as leaky pneumaUc drivers, electronic failures, corrosion, and sticking valves. 

6) Extreme environmental conditions includes unusually low temperature (instrument air/control system freezing), extremely heavy rainfall (high flow, 

low temperature to strippers), high cooling water temperature. 

7) Poisoning of catalyst in manufacturing unit from feed contamination. Also catalyst poisoning in catalytic combustion device. 

8) Fuel to control device has temporary deviation in heating value or content. Fuels are generally supplied by external vendors and may have variations 

in Btu content, composition, or impurities yielding temperature deviations. 

9) Cooling water contamination may take die form of organic, sediments, pump or treatment (screening) problems, or biological fouling. 

10) Vendor error may result from attempts to design to very stringent complex standards on a large number of emissions points within limited design 

lime. Typical problems include those in measurement systems, materials of construction and impacts of multiple streams into control devices. 
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HON COMPLIANCE ISSUES 

Issue: How many excursions should be "allowed"? 

• Example with 1% of operating time allowed to be in excursions 

• Assume: (1) Processes run 365 days/yr; 

(2) Processes run 24 hours/day; so 

(3) Monitors run 8760 hours/yr. 

(4) Thus, there are 2920 monitoring periods per year (3-

hour). 

(5) 1% of annual monitored periods = 29.2 monitored 

periods per year. 

(6) 1% of quarterly monitored periods = 7.3 monitored 

periods/quarter. 

• Could "allow" or "excuse" 7 monitored periods/quarter. 

• Could "allow" or "excuse" 1% of monitored periods/quarter. 

Would link-up with the semi-annual to quarterly reporting 

requirement. 

• Either option above would allow no more than 21 hours/quarter of 

excursions. 

Stating requirement as a % could reduce the number of 

hours/quarter in "excused" excursions.