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OAR Box 1878 

Prepped by Charmelle Mathews 

Document Number: 

133) ll-E-17 

Docket Number: 

A-90-19 

Printed 11/28/2008 1:21:26 PM Sheet 133 of 145 
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\ 

4 CORPORATIO

RADIAN

N 

 A-90-19 

ll-E-17 

MEMORANDU M 

TO: Jan Meyer 

FROM: Bennett King ',"!"© ^ ^ ^' *': 

DATE: September 14, 1992 ,;," . • o ingO 

SUBJECT: EPA/SOCMA Meeting on January 15, 1991 

ATTENDEES: See Attachment 1 

«•»«..' c * * 

This was the second meeting between the EPA and the 

Synthetic Organic Chemical Manufacturers Association (SOCMA) 

concerning the Hazardous Organic NESHAP (HON) program and served 

as a follow-up to the initial meeting in Washington, D.C. on 

November 26, 1992. The highlights of the meeting are presented 

below. 

• In the previous meeting, the EPA had asked the SOCMA to 

provide production capacity information for a list of 

chemicals. The SOCMA conclusion is that it is 

difficult to obtain the production capacity information 

requested by the EPA. However, they have found some 

information by contacting their member companies. A 

preliminary response was prepared and will be updated 

over the next two weeks. The EPA can expect to receive 

the information from the SOCMA by the end of January. 

The SOCMA agreed to try and supplement the originally 

requested information with data on size of businesses 

(number of employees). This additional information was 

requested by Tom Walton (EPA/CEIS). 

• A lengthy discussion concerning batch operations took 

place. The SOCMA's primary concern was that the EPA 

understand the potential errors in calculating 

potential emissions or capacities for multi-use batch 

operations. Where a multi-use batch operation can 

potentially produce 20 Gg/yr of product A and 15 Gg/yr 

of product B, the capacity for this operation is not 

35 Gg/yr. Other points that came up during this 

discussion were: 

The EPA clarified that the process vents portion 

of the HON would not regulate batch processes. 

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The EPA and the SOCMA agreed on the EPA definition 

of a batch process as found in the Reactor New 

Source Performance Standard (NSPS), "...cannot 

simultaneously withdraw product and introduce raw 

material..." 

The storage portion of the HON is of special 

concern to batch operators. Many small (< 12,000 

gallons) tanks are present at batch process units. 

The EPA clarified to the SOCMA that storage of a 

hazardous air pollutant (HAP) would only be 

regulated if that storage was associated with a 

regulated production process. 

The SOCMA characterized its membership and the 

population of small companies as follows (these are 

rough estimates): 135 SOCMA manufacturing members, 35% 

have less than 10 employees, 65% (including the 35%) 

have less than 50 employees. In addition to the SOCMA 

membership, another 800 manufacturing companies, 

similar to the SOCMA membership, are believed to exist. 

The SOCMA expressed concern that the HON allow 

alternative control methods. The EPA explained that 

the HON would not only allow but encourage the use of 

product recovery and/or alternative control methods. 

This will be accomplished by allowing an operator to 

reduce emissions or stream characteristics below the 

applicability criteria. Specific points were brought 

up concerning the storage and wastewater portions of 

the HON. 

The SOCMA reiterated their concern with the many 

small tanks found in batch operations and in small 

continuous operations as well. They asked if 

floating roofs would be required on these small 

(< 12,000 gallons) tanks. The EPA stated that 

floating roofs would not be required for tanks 

less than 20,0.00 gallons where application is 

technically infeasible. However, add-on controls 

(e.g., condensers) would be required. 

The SOCMA stated their desire to see alternative 

wastewater treatment methods allowed by the HON, 

especially the use of biological treatment. The 

EPA reiterated the point that an operator can 

always take actions to get below the applicability 

criteria. The EPA also cited the general 

provisions statement that any alternative control 

technology could be used with approval from the 

Administrator of the EPA. The SOCMA requested a 

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copy of the Wastewater Technical Information 

Document recently published by the EPA. 

Penny Lassiter agreed to send SOCMA a copy. 

A short discussion concerning Maximum Achievable 

Control Technology (MACT) for new versus existing 

sources took place. The concept of a MACT "floor" was 

also discussed. The EPA stated that the approach for 

determining the floor would be based on an analysis of 

federal and State regulations. 

A short discussion of the Batch Processes Control 

Techniques Guideline (CTG) took place. The EPA 

informed the SOCMA that Section 114 responses had been 

received, streams were characterized, cost estimates 

were being developed, and a draft of the CTG was 

expected this fall. The EPA informed the SOCMA that 

the scope of the Batch Processes CTG does not include 

wastewater or storage operations. 

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ATTACHMENT 1 

Name 

Bennett King 

Leslie Evans 

Bob Rosensteel 

Penny Lassiter 

Linda Chaput 

Randy McDonald 

Mary Legatski 

Bob Campaign 

Ralph Johnson 

Affiliation 

Radian Corporation 

EPA/CPB 

EPA/CPB 

EPA/CPB 

EPA/SDB 

EPA/CPB 

SOCMA 

UpJohn 

Dixie Chemical 

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