p.1 

OAR Box 1669 

Prepped by Charmelle Mathews 

Document Number: 

j{^g, ll-E-15 

Docket Number: 

A-98-13 

Printed 9/23/2008 9:36:49 AM Sheet 83 of 110 
P.2 

/K-%-13 

MEMORANDUM 

TO: Project File 

Organic Liquids Distribution NESHAP 

ESD Project No. 96/05 

FROM: Bernd Haneke 

Pacific Environmental Services, Inc. 

DATE: June 12,1998 

P :\n812\meetings\nacdtele. wpd 

SUBJECT: Minutes ofthe Information Collection Request Teleconference 

National Association of Chemical Distributors (NACD) 

I. Purpose 

The purpose ofthis teleconference was to provide National Association of Chemical 

Distributors (NACD) member companies an opportunity to ask the EPA project team questions 

related to the EPA's Information Collection Request (ICR). In turn, the teleconference provided 

the EPA project team with an opportunity to identify and address problem areas within the ICR 

as it pertains to NACD member facilities. 

II. Location 

U.S. Environmental Protection Agency 

EPA/NC Mutual Building 

Durham, North Carolina 

June 5,1998,10:00 -11:00 am 

III. Participants 

National Association of Chemical Distributors (NACD;) 

Bill Allmond - Manager of Regulatory Affairs 

Geoff O'Hara - Director of Government Affairs 

Industry Representatives 

Andy Cuthbert - Holland Chemical International 

Rick King - Continental Industrial Chemicals 

Miranda Middleton - Superior Oil Company 

Pete Mirali - Soeo Chemical, Inc. 

Tom Nisler - Van Waters and Rogers 
NACD Teleconference Minutes 

June 12,1998 

Page 2 

Bob Smith - Soeo Chemical, Inc. 

Don Williams - Ellis and Everard (US Holdings, Inc.) 

Richard Wright - Ashland Chemical Company 

U.S. Environmental Protection Agency (EPA) 

Steve Shedd - OAQPS/ESD/WCPG, Research Triangle Park, NC 

Pacific Environmental Services. Inc. 

Bernd Haneke - RTP, NC 

Greg LaFlam - RTP, NC 

IV. Teleconference Summary 

Bill Allmond, NACD, opened the meeting by introducing himself and asking for the other 

participants to join in a roll call. After the roll call was completed, Mr. Allmond explained that 

the purpose ofthe teleconference was to offer NACD member facilities an opportunity to ask the 

EPA project team ICR specific questions. Mr. Allmond then turned the teleconference over to 

Steve Shedd. 

Mr. Shedd began the meeting by stating that he would proceed by reading the questions in 

the order in which they appeared in an E-mail sent to the EPA by NACD, and that he would also 

elaborate on the preliminary answers he provided to NACD in his May 26th E-mail 

(Attachment). He added that the EPA project team would field any questions that industry 

representatives might raise during the phone call. 

What follows is a detailed listing of questions and answers that were discussed during the 

teleconference. 

1. Question: Are fugitive emissions counted toward the HAP threshold? 

Answer: Yes, they are. All HAP emissions must be accounted for from the entire 

plant site. 

2. Question: What level of documentation does the EPA expect to show that facility 

emissions are below the threshold? 

Answer: A written assessment is required to be shown upon request. However, 

the EPA is not currently asking for that documentation to be submitted. This information 

should be kept on file along with other ICR-related materials at the plant site/facility. 

3. Question: Does the EPA plan to resurvey if too few facilities exceed the thresholds? 

Answer: Currently, the EPA does not plan to resurvey the industry. However, the option 

is available should it be necessary. 

1 
P.4 

NACD Teleconference Minutes 

June 12,1998 

Page 3 

4. Question: Does the EPA plan to lower the thresholds if it finds low facility applicability? 

Answer: We have no plans to lower the size facility threshold because of low returns. 

However, we will assess at some point in time two associated issues that might cause a 

need for lowering the threshold, which are: 

a) The EPA will do a risk assessment of smaller sources to determine if there 

is a health threat and ifso, the EPA would propose standards for smaller sources. 

b) The EPA will do an assessment to determine if there is a lower size 

applicability cutoff that could be used in the rule without the need for prior 

enforceable limits. 

5. Question: Do all of our sites need to complete Section J of the survey? 

Answer: There was some confusion regarding this question, as it was determined that 

the author ofthe question had confused issues and looked at the wrong Section J. 

6. Question: A facility repackages a total of 31,870 lb of butyl oxitol (a glycol ether). 

With an estimated loss of less than 1 percent, please confirm that the facility would 

be well below the HAP emissions threshold of 5 tpy ofany single HAP. 

Answer: Using mass balance equations or good engineering judgement suffices in 

deriving a conclusion that this is not sufficient (300 lb) to release 5 tpy of HAP. 

A justification ofemissions calculations methodology used would also be helpful. 

7. Question: There is a concern that the EPA may be compiling a list of companies for 

future enforcement action. Is the EPA able to confirm or deny this concern? 

Answer: There is no intent and no discussion to use company/facility lists from this 

survey for any enforcement activity. The Emission Standards Division of OAQPS does 

not handle enforcement actions. Mailing lists are available to enforcement groups within 

the EPA, and therefore we cannot guarantee that no enforcement action could be 

facilitated through use of these lists. 

Teleconference participants asked Mr. Shedd how they could become a member ofthe 

Roundtable discussions. Mr. Shedd replied that Mr. Allmond was already on the Roundtable, 

and would represent the NACD there. Another participant asked ifthe EPA project team was 

planning further site visits. Mr. Shedd responded that more visits were planned, but that these 

would be to larger facilities than those previously visited. Future facilities would most likely 

also be those that respond to the ICR. 

One participant asked if low quantities of blends should be reported in the ICR, to which 

the EPA project team responded that this would be necessary. It was also mentioned by the 

project team that rather than listing individual blends, families of blends should be listed. 

Furthermore, when listing only families of blends, average values can be submitted in lieu of 

detailed information about each blend or compound produced at the plant site. 

3 
P.5 

NACD Teleconference Minutes 

June 12,1998 

Page 4 

Another participant asked if there would be an extension ofthe July 8,1998 response 

deadline. Mr. Shedd responded that the deadline would be extended to August 3, 1998, and that 

an official E-mail and letter from the EPA would verify this. Mr. Shedd also mentioned that this 

information would be posted on the EPA's TTN website. 

To conclude the meeting Geoff O'Hara, NACD, recapped the four most important points 

ofthe meeting as follows: 

1. Families of blends can be included in the ICR in lieu of listing each individual blend; 

2. Ifa company does not have any facilities for which it must report its emissions, then a 

simple letter stating that fact will suffice for the EPA's purposes; 

3. Mass balance equations and good engineering judgement are sufficient for emissions 

estimations and calculations; and 

4. There has been a time extension from July 8, 1998 to August 3,1998, for facilities to 

respond to the survey. 

V. Conclusion 

Following the brief summary ofthe most important meeting issues, the EPA project team 

thanked the NACD for their time and the teleconference was adjourned. 

4 
P.6 

ATTACHMENT 

5 
P.7 

From: BILLNACD <BILLNACD@aol.com> 

Date sent: Thu, 14 May 1998 09:50:26 EDT 

To: SHEDD.STEVE@epamail.epa.gov 

Copies to: glaflam@rtp.pes.com 

Subject: HAP Survey 

Steve, a couple of questions... a number of our members who received 

the HAP survey have relayed concerns to us about the July 8 deadline. 

The concerns came from both large and small companies. What is the . 

process for requesting a reasonable extension on behalf of our member 

companies on the list? We would like to have an extension of at least 

60 days if possible. 

Also, I do not expect many will be attending the workshop in June, 

because of time commitments. Therefore, we strongly encourage the 

opportunity of having a conference call between member companies on 

the list and EPA. Rather than have open dialogue with all 29 members, 

we are requesting that they submit specific questions about the survey 

to us. We would then forward them to you prior to the call. During the 

teleconference, we would have designated speakers from our group 

dialogue with you, with everyone else listening to the discussion. 

We want to continue to work with EPA on this issue and to provide 

assistance to members in the process. I look forward to your response. 

Thanks, Bill 

Greg LaFlam - 1 - Fri, 29 Jan 1999 10:44:15 

(P 
P.8 

Date sent: Tue, 26 May 1998 15:40:21 -0400 

From: STEVE SHEDD <SHEDD.STEVE@epamail.epa.gov> 

Subject: List of MACT survey questions -Reply 

To: BILLNACD@aol.com 

Copies to: bhaneke@rtp.pes.com, glaflam@rtp.pes.com 

Bill, 

June 1 through the am of June 4 does not work for us due to the 

workshop in Tx. So I would suggest that we do the conference call in 

the am on June 5th (starting as early a 9am). Are you arranging the 

phone tie-in? Below is a quick response to your questions and we can 

more fully discuss next week. Please pass along to originators of 

the questions. Steve 

Stephen Shedd 

U.S. EPA 

Office of Air Quality Planning and Standards 

Research Triangle Park, NC 27711 

voice: (919) 541-5397 

fax:(919)541-0246 

E-mail: shedd.steve@epa.gov 

> » BILLNACD <BILLNACD@aol.com> 05/26/98 11:55am > » 

Steve, 

Below are several questions that we have received from members 

regarding the survey information. I anticipate we will receive several 

more within the next 2 weeks. We would like to move forward with a 

conference call between interested NACD members who received the 

survey and EPA. The first week in June (next week) would be good. AM 

on the June 1st or June 4th is good or anytime June 5th. Alos, the 

week of June 8th appears open on my calendar. Again, the purpose of 

the meeting is to address pre-submitted questions from member 

companies. I anticipate low member turnout at the Houston workshop. 

Therefore, I propose conducting this conference call as an 

alternative. 

Questions received: 

-are fugitive emissions counted toward the HAP threshold? yes they 

are. All emissions must be accounted for from the entire plant site, 

-what level of documentation does EPA expect to show that facility 

emissions are below the threshold? I would expect that a written 

assessment of emissions would be required to be shown upon request. 

However, we are currently NOT asking for that documentation to be 

submitted, -does EPA plan to re-survey if too few facilities exceed 

the thresholds? We have no plans to re-survey at this time. However 

that option is always available if issues arise, -does EPA plan to 

lower the thresholds if it finds low facility applicability? We have 

no plans to lower the size facility threshold because of low returns. 

However we will assess at some point in time two associated issues 

that might cause a new need. (1) We will do a risk assessment of 

smaller sources to determine if there is a health threat and if so we 

would propose standards for the smaller sources (so called non-major 

sources) and (2) We will do an assessment to determine if there is a 

lower size aplicablity cutoff that could be used in the rule, to allow 

small sources out of the rule without the need for prior enforceable 

limits, -do all of our sites need to complete Section J of the 

survey? I do not understand the question. Subsection J of Section I, 

only contains the address of where to send the response, -we 

repackaged a total of 31,870 lbs. of butyl oxitol. With an estimated 

loss of less than 1%, please confirm we would be well below the HAP 

emissions threshold of 5 tons per year of any single HAP. We need to 

discuss and look into. Is the product a HAP or contain HAPs? I will 

GregLaFtam -1 - Fri, 29 Jan 199910:45:43 

1 
P.9 

have PES look into this, -there is a concern that EPA may be 

compiling a list of companies for future enforcement action. Is EPA 

able to confirm or deny this concern? There is no intent or has there 

been any discussion to use company/facility lists from this survey for 

any enforcement actions. The office I am in, does not do enforcement 

actions. 

Regards, 

Bill Allmond 

Greg LaFlam - 2 - Fri, 29 Jan 1999 10:45:43 

b