p.1 

OAR Box 1875 

Prepped by Ollie Stewart 

Document Number: 

25) ll-E-43 

Docket Number: 

A-90-19 

Printed 12/1/200811:12:45 AM Sheet 25 of 86 
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A-90-19 

ll-E-43 

DATE: May 26, 1992 

SUBJECT: Hazardous Organic NESHAP (HON) Meeting with State 

Representatives 

PLACE: Washington, D.C - NGA Office 

The following EPA personnel participated in a meeting on the HON 

with members of the National Governors Association's Air 

Implementation Task Force: Daphne McMurrer, Standards 

Development Branch; Bruce Jordan, Director of the Emissions 

Standards Division; and Lydia Wegman, Deputy Director of the 

Office of Air Quality Planning and Standards. A handout provided 

by EPA at the meeting is attached. 

Attachment: 1 

mgmll.memos.dct 
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HON Overview 

Subpart F: 

Subpart G: 

Subpart H: 

Applicability and General Requirements 

Provisions for SOCMI Process Vents, Storage 

Vessels, Transfer Operations and Wastewater 

Point by Point Compliance Requirements 

Emissions Averaging Compliance 

Requirements 

Provisions for SOCMI and non-SOCMI Equipment 

Leaks 

How does Emissions Averaging fit with the rest of the HON? 

Only allowed for SOCMI Process Vents, Storage 

Vessels, Transfer Operations and Wastewater 

Is an alternative way to comply with the HON—T 

designed to achieve equivalent or greater emissions 

reductions as point by point compliance 

Uses the same compliance procedures, performance 

tests and parameter monitoring, but also has an 

emissions estimation component 

What are the Emissions Averaging Requirements? 

Specific control commitments for each point in an 

average 

Specific limitations on which controls can be used 

to generate credits 

Controls that are more stringent than 

required for the given point 

Controls that were not in place for other 

purposes, except 

Early Reductions Controls 

Pollution Prevention Actions 

Specific procedures for assigning the amount of 

credits generated by an overcontrolled point 

Use of a Discount Factor 
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HON Emissions Averaging 

Compliance Issues 

Without Emissions Averaging: 

All Group 1 points have control, monitoring, 

recordkeeping and reporting requirements 

Some Group 2 points have monitoring, recordkeeping and 

reporting requirements 

With Emissions Averaging: 

All the points included in an average have monitoring, 

recordkeeping and reporting requirements 

Credit generating points (either Group 1 or Group 2) have 

control commitments that are separately enforceable from 

the average's credit/debit balance 

These control commitments are listed in the HON 

Implementation Plan and the Operating Permit 

The credit/debit balance can be enforced using the 

required records of operating parameters and the 

emissions estimation equations in the HON 

Steps in the HON Implementation and Enforcement Process 

Determination of all Group 1 and Group 2 points 

Selection of a Control Approach 

Point by Point Control 

Emissions Averaging 

A Combination of Point by Point and Emissions 

Averaging 

Selection of Specific Control Devices for Each Emission 

Point 

Numerous Alternative Devices Allowed for Each Kind 

of Emission Point 

Each Alternative Device has Specific Implementation 

Requirements (Monitoring & Recordkeeping) 
P.5 

irS 

HON Emissions Averaging 

Compliance Issues 

Continued 

Steps in the HON Implementation and Enforcement Process (Cont.) 

Performance Test or Inspection for Each Control Device 

Prove that control achieves the desired emissions 

reductions (reference control efficiency rating) 

Set Range for Acceptable Operating Parameters for 

the Continued Operation of the Control Device 

Parameter Monitoring for all Group 1 and some Group 2 

Points 

Report "Exceedances" of the Acceptable Operating 

Parameter Ranges each Quarter 

Used to Signal Changes in Group 1 or Group 2 Status 

New Group l/Group 2 Determinations if the Production 

Process Changes 

New Performance Test if the Production Process Changes 

for Already Controlled Group l Points 

for Newly Controlled Group 1 Points 

For Emissions Averaging, Periodic Calculation of the 

Credits and Debits from Monitored Operating Parameters 

Emissions Averaging Increases: 

the Number of Emission Points with Detailed Compliance 

Requirements 

the Amount of Data that Must Be Collected (the Number of 

Operating Parameters Monitored) to Cover all the Inputs 

into the Emissions Estimation Equations