p.1 

OAR Box 1875 

Prepped by Ollie Stewart 

Document Number: 

60) ll-F-7 

Docket Number: 

A-90-19 

Printed 12/1/200811:12:47AM Sheet 60 of 86 
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A-90-19 

ll-F-7 

Attached are materials distributed by the EPA at a meeting 

with OMB on August 11, 1992 (a.m.). Below is a list of 

attendees. 

EPA 

Jan Meyer 

Daphne McMurrer 

Bruce Jordan 

Lydia Wegman 

Andrew Otis 

Patricia Embrey 

OMB 

Tim Hunt 

Troy Hillier 

Rick Belzer 

Steve Aitken 

Shantale Wong 

! 1992 y ^ 

L EPA AIR DOCKET 
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EPA/OMB Meeting on Floor Determination Process 

Potential concerns with the process used to determine the 

floors 

Combining data on the emission points to develop the 

source-wide floor 

Consideration of points which had less than 12 percent 

controlled with the RCT 

Use of the 12th percentile vs. the average performance 

of the best performing 12 percent 
P.4 

Combination of Data on the Individual Points to Determine 

the Source-wide Floor 

BACKGROUND 

• Emissions and characteristics of SOCMI sources vary 

widely from plant site to plant site 

Each is unique combination of processes, design 

characteristics, equipment and operations 

No "typical" source for this source category 

Our analyses are not based on one model plant, 

but instead on model emission streams. There are: 

95 model vent streams 

400 model wastewater streams 

9 model tank farms 

21 model transfer racks 

• Common characteristics of SOCMI sources are the 

generic emission points and applicable control 

techniques 

• TX and LA have majority of SOCMI facilities and have 

rules regulating emissions from vents, storage vessels, 

and transfer racks 

requirements are similar to CTG's (and our RCT) 
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CONCLUSIONS 

By expressing the source-wide floor as equation 

consisting of terms for each kind of emission point, the 

resultant floor would comply with the statute 

any single emission rate, % reduction, etc. that 

was derived from the impact analyses: 

O would allow some processes to be uncontrolled 

O would not be achievable for some processes 

Allows for equitable treatment of all SOCMI 

sources 

• Most consistent with existing rules for SOCMI sources 

and with the technology based standards data base 

used to support this rulemaking 

• Disadvantages of developing a single performance level 

to represent the source-wide floor include: 

does not allow for site specific variations (sum of 

the part approach of does); has potential for 

limiting growth and operational flexibility 

does not reflect changes in design and operation of 

processes over time 

assumptions required to estimate a source-wide % 

reduction or mass of emissions 
P.6 

Consideration of Points Which Had Less Than 12 Percent 

Controlled With The RCT 

BACKGROUND 

• Process 

for each kind of emission point, arrayed the 

database by emission characteristics (i.e., physical 

parameters such as flow rate, HAP concentration, 

and vapor pressure) 

ordered from low to high emission potential (or 

surrogate measure) 

Cumulative percent controlled with the reference 

technology(ies) was calculated 

Boundary at which at least 12% of the points were 

controlled by the RCT used to define the emission 

characteristics associated with the best performing 

12% 

The calculation of the average was omitted 

because all points assigned the same 

efficiency 

CONCLUSION 

• No control efficiency was assigned to points below the 

12% boundary because there is no widely applicable 

technology that provides the partial control when 

properly operated and maintained 

• No partial control options available for nationwide rule 
P.7 

12th Percentile vs. Average of the Best Performing 12 

Percent 

BACKGROUND 

• Database reflects any controls that would be required 

by applicable state or Federal regulations 

• These regulations typically require use of most effective 

control technologies (or performance levels) that are 

generally applicable 

Controls either work or don't work; wide range of 

control efficiencies are not available 

Distinction is controlled vs. uncontrolled (e.g., 0 

vs. 98% reduction) 

CONCLUSION 

• In this case, the average achieved by the best 

performing 12 percent is the same as the 12th 

percentile performance level. 

• Approach does not imply a precedent for future 

standards 
P.8 

Summary of Floor Analyses 

Process Vents 

Ranked by C/E from high to low; ranged from $184 

billion/Mg to $4/Mg 

12% controlled at C/E <$1,500/Mg 

• 44% of vents with C/E <$1,500/Mg 

controlled by 98% device 

• 10% of vents with C/E >$1,500/Mg 

controlled by 98% device 

Storage Vessels 

Examined model tanks in 3 groups 

For each group, ranked by vapor pressure from low 

to high (i.e., high C/E to low C/E) 

10,000 to 20,000 gallons: 

• no tanks controlled at any vapor pressure 

20,000 to 40,000 gallons: 

• 0% of tanks with vp < 1.9 psia controlled 

• 17% of tanks with vp > 1.9 psia controlled 

40,000 gallons & up: 

• 7% of tanks with vp < 1.9 psia controlled 

• 23% of tanks with vp > 1.9 psia controlled 
P.9 

• Transfer Operations 

Examined model racks in 2 groups 

For each group, ranked by throughput from low to 

high (i.e., high C/E to low C/E) 

12% found 

• racks with vp < 1.5 psia: 

no controlled racks at any throughput 

• racks with vp > 1.5 psia: 

no controlled racks with throughputs < 

0.17 MMGal/yr 

Wastewater 

The two relevant regulations (Vinyl Chloride 

NESHAP and Benzene Waste NESHAP) either 

control all streams or no streams 

• Different approach used: examined 

percentage of all processes and streams 

controlled 

Found only 2.5% of the streams and only 5.1% of 

processes controlled for air emissions