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OAR Box 1875 

Prepped by Ollie Stewart 

Document Number: 

1) ll-E-19 

Docket Number: 

A-90-19 

Printed 12/1/200811:12:43 AM Sheet 1 of 86 
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• > * A-90-19 

ll-E-19 

^

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. UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

*&amsj I Office of Air Quality Planning and Standards 

^y^ £ / Research Triangle Park. North Carolina 2 77* 1 

0 7 FEB 1991 

MEMORANDUM *~ 

[i fe. M

 v "•:' 

DECIBI99 2 ', 

SUBJECT: Meeting with Debbie Sheiman of the National Resource 

Defense Council (NRDC) to Discuss Hazardous Organic 

NESHAP Rulemaking 

FROM: Robert E. Rosensteel, Chief I 

Chemical Manufacturing Section, CPB/ESD (MD-13) 

TO: Susan R. Wyatt, Chief 

Chemicals and Petroleum Branch, ESD (MD-13) 

On January 16, 1991, Ms. Linda Chaput and myself met with 

Ms. Debbie Sheiman of the NRDC to discuss the HON project. The 

attached briefing paper was used as a guide in our discussion of 

our work. Ms. Sheiman raised two primary questions in the 

discussion; the first concerned why we were not using actual 

plant data to establish the MACT floors rather than State 

regulations and for sources affecting process vents, storage, 

transfer, and wastewater operations emission points. We 

explained that we do not have plant data allowing us to make this 

calculation, and to obtain such data for a sufficient number of 

plants to make a reliable estimate of the best performing 

existing 12 percent of sources would require too much time to 

accomplish within our schedule. The second question Ms. Sheiman 

raised concerned the performance level of 98 percent reduction 

for combustion devices and why couldn't we require even a higher 

reduction than 98 percent since some sources operate at a higher 

efficiency than 98 percent. It was explained that we simply 

don't have the data to determine whether a more stringent level 

could be required, and it is not possible to obtain such data 

given the tight schedule that we have. 

Attachment 

cc: Linda Chaput 

Leslie Evans 
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BACKGROUND INFORMATION FOR THE 

HAZARDOUS ORGANIC NESHAP (HON) 

NRDC - EPA MEETING 

WASHINGTON, D.C. 

JANUARY 16, 1991 
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PURPOSE: TO PROVIDE INFORMATION CONCERNING THE SCOPE OF THE HON, 

DESCRIBE THE CONTROL TECHNIQUES THAT WILL BE ANALYZED FOR 

REDUCING EMISSIONS, AND DESCRIBE THE ANALYTICAL APPROACH TO 

ESTIMATE NATIONAL IMPACTS OF CANDIDATE REGULATORY ALTERNATIVES 
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SCOPE OF HON 

• THE SYNTHETIC ORGANIC CHEMICAL MANUFACTURING INDUSTRY (SOCMI) 

INCLUDES THE PRODUCTION OF SOME 600+ CHEMICALS 

• THE HON SCOPE INCLUDES (1) SOCMI PROCESSES THAT (A) PRODUCE A HAP ON 

THE CAAA LIST OF 189, OR (B) USE (AS REACTANT) ONE OR MORE HAP TO 

PRODUCE A CHEMICAL, and (2) EQUIPMENT LEAKS FOR PRODUCTION OF 

STYRENE-BUTADIENE RESINS, POLYBUTADIENE, PHARMACEUTICALS (PROCESS 

SOLVENT), PESTICIDES (PROCESS SOLVENT), CHLORINE AND MISCELLANEOUS 

BUTADIENE PRODUCTS 

• ABOUT 400 CHEMICALS HAVE BEEN IDENTIFIED THAT FALL WITHIN THE HON 

SCOPE 

• TO DATE WE HAVE IDENTIFIED AN AVERAGE OF 1.4 ROUTES TO PRODUCE EACH 

CHEMICAL, EACH ROUTE TO PRODUCE A CHEMICAL IS DEFINED AS A PRODUCT 

PROCESS 

• THEREFORE OVER 600 PRODUCT PROCESSES MAY ULTIMATELY BE 

SUBJECT TO THE RULE 

. CURRENT SCHEDULE CALLS FOR PROPOSAL IN NOVEMBER 1991 AND PROMULGATION 

IN NOVEMBER 1992 (WITHIN TWO YEARS OF CAAA ENACTMENT) 
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REGULATIONS HAVE BEEN DEVELOPED FOR 

SOCMI AND RELATED EMISSION SOURCES 

. PROCESS VENTS 

AIR OXIDATION PROCESSES (NSPS PROMULGATION) 

DISTILLATION OPERATIONS (NSPS PROMULGATION) 

REACTOR PROCESSES (NSPS PROPOSAL) 

• EQUIPMENT LEAKS (NSPS AND BENZENE NESHAP PROMULGATION) 

• VOLATILE ORGANIC LIQUID STORAGE (NSPS PROMULGATION) 

• BENZENE NESHAP HAS BEEN DEVELOPED FOR EMISSIONS FROM 

WASTEWATER AND TRANSFER OPERATIONS 

. THESE RULES AND DATA FROM THEIR ANALYSES WILL BE USED 

TO AID IN IDENTIFYING CONTROL TECHNOLOGIES, AND TO HELP IN 

ESTABLISHING FLOORS FOR EXISTING SOURCES, 
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IT IS ANTICIPATED THAT THE HON WILL 

REGULATE THESE EMISSION SOURCES 

PROCESS VENTS (CONTINUOUS PROCESSES) 

EQUIPMENT LEAKS 

STORAGE VESSELS 

TRANSFER 

WASTEWATER 
P.8 

CONTROL TECHNIQUES THAT ARE CANDIDATES FOR MACT: 

PROCESS VENTS 

NON - CHLORINATED ORGANIC VAPOR CONTAINING 

STREAMS - 98% COMBUSTION 

HALOGENATED ORGANIC VAPOR CONTAINING 

STREAMS - 98% COMBUSTION BY INCINERATION PLUS 

SCRUBBING 

EQUIPMENT LEAKS 

RESULTS OF THE REGULATORY NEGOTIATION 
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CONTROL TECHNIQUES THAT ARE CANDIDATES FOR MACT: 

(CONTINUED) 

STORAGE VESSELS 

UNDERGROUND OR HORIZONTAL VESSELS - REFRIGERATED 

CONDENSERS 

NON CHLORINATED - FIXED ROOF TANKS WITH INTERNAL 

FLOATING COVER HAVING ACCEPTABLE SEAL(S) 

CHLORINATED - REFRIGERATED CONDENSER 
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CONTROL TECHNIQUES THAT ARE CANDIDATES FOR MACT: 

(CONTINUED) 

TRANSFER 

NONCHLORINATED - 98% COMBUSTION DEVICE 

CHLORINATED - 98% INCINERATOR + SCRUBBING 

WASTEWATER 

STEAM STRIPPING OF AQUEOUS WASTE STREAM + WATER 

COOLED CONDENSER + REFRIGERATED CONDENSER 
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INDUSTRIAL PROFILE SPECIFICS 

PURPOSES 

• CHARACTERIZE INDUSTRY . . . CHEMICALS PRODUCED, PROCESSES 

USED, MANUFACTURING LOCATIONS, EMISSION SOURCES 

• DEVELOP A STRUCTURE TO USE INDUSTRY CHARACTERISTICS AND 

CALCULATE BASELINE EMISSIONS, EMISSION REDUCTIONS, CONTROL 

COSTS AND OTHER IMPACTS (FRAMEWORK DATABASE SYSTEM) 

• PROVIDE MECHANISM FOR EVALUATING REGULATORY ALTERNATIVES 
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INDUSTRIAL PROFILE SPECIFICS 

(CONTINUED) 

FEATURES 

• IDENTIFYING UNIQUE WAYS TO PRODUCE EACH CHEMICAL 

(PRODUCT-PROCESSES), HOW MUCH IS PRODUCED, AND WHO 

PRODUCES IT 

. FOR EACH EMISSION SOURCE TYPE, ASSIGN EMISSION ANO 

CONTROL/COST MODELS TO EACH PROOUCT-PROCESS 

• MODELS WILL CALCULATE VALUES FOR EACH PROCESS 

UNIT USING PARTICULAR PRODUCT-PROCESS CHARACTERISTICS 

• OUTPUT FILES CONTAINING BASELINE EMISSIONS AND EMISSION 

REDUCTIONS, CONTROL COSTS, AND OTHER IMPACTS FOR EACH 

CONTROL OPTION (CONTROL TECHNOLOGY) AT THE PROCESS UNIT 

LEVEL 

• RESULTS: MAXIMUM FLEXIBILITY IN SELECTING AND EVALUATING 

REGULATORY ALTERNATIVES 

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INDUSTRIAL PROFILE SPECIFICS 

(CONTINUED) 

STEPS IN CHARACTERIZING INDUSTRY 

• REVIEW OF READILY AVAILABLE LITERATURE 

• ANALYSIS OF LITERATURE TO DETERMINE . . 

NATIONAL CAPACITY AND PRODUCTION 

MARKET PRICE 

INDIVIDUAL PRODUCERS AND CAPACITIES 

UNIQUE COMMERCIAL PRODUCTION PROCESSES 

(PRODUCT-PROCESSES) 

FOR EACH PRODUCT-PROCESS 

RELATION OF REACTANTS AND PRODUCTS TO 

KNOWN PRODUCT CAPACITY (KG/KG PRODUCT) 

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P.14 

INDUSTRIAL PROFILE SPECIFICS 

(CONTINUED) 

FRAMEWORK DATABASE SYSTEM 

• INPUTS ... 

INDUSTRY CHARACTERISTICS 

BASELINE CONTROL LEVEL-STATE REGULATIONS, NESHAP 

EMISSION MODELS-ALGORITHM TO CALCULATE BASELINE EMISSIONS 

CONTROL MODELS-ALGORITHM TO CALCULATE EMISSIONS REDUCTIONS 

AND COSTS FOR A SPECIFIC CONTROL OPTION (CONTROL TECHNOLOGY) 

(MODELS DEVELOPED BY FIVE HON REGULATORY PROJECTS) 

• OUTPUTS . . . 

BASELINE EMISSIONS 

EMISSION REDUCTIONS (FOR EACH CONTROL OPTION) 

CONTROL COSTS (FOR EACH CONTROL OPTION) 

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INDUSTRIAL PROFILE SPECIFICS 

(CONTINUED) 

METHODOLOGY 

• INDUSTRY CHARACTERISTICS IN DATABASE ON PRODUCT-PROCESS 

BASIS 

• LARGELY AUTOMATED PROCESS FOR ASSIGNING EMISSION AND 

CONTROL MODELS TO PRODUCT-PROCESSES 

• COMPLETELY AUTOMATED PROCESS FOR CALCULATING BASELINE 

EMISSIONS, EMISSION REDUCTIONS, AND CONTROL COSTS ONCE 

MODELS ARE ASSIGNED TO PRODUCT-PROCESSES 

• WE WILL PROJECT NATIONAL IMPACTS BASED ON THE PRODUCTPROCESSES COMPLETELY DEFINED 

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THE ROLE OF ECONOMIC ANALYSES 

ECONOMIC ANALYSES INVESTIGATE THE BEHAVIORAL RESPONSE TO REGULATIONS 

• CHANGES IN PRICE, PRODUCTION, EMPLOYMENT, MARKET STRUCTURE 

. DISTRIBUTION OF THE COST OF CONTROL 

THE RESULTS OF THE ANALYSES ARE CONSIDERED IN DETERMINING THE FORM 

AND STRINGENCY OF THE STANDARD 

• BOTH PRIVATE AND SOCIAL COSTS ARE CONSIDERED 

• ARE THE SOURCES TO BE REGULATED SIMILAR TO THOSE FOR WHOM THE 

CONTROL HAS BEEN DEMONSTRATED? 

THE RESULTS ARE USED TO DETERMINE IF OTHER ANALYSES ARE NEEDED 

• REGULATORY FLEXIBILITY ANALYSIS (SMALL BUSINESS CONCERNS) 

. REGULATORY IMPACT ANALYSES (MAJOR REGULATIONS) 

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CHALLENGES FOR HON ECONOMIC ANALYSES 

BREADTH 

• THE HON WILL COVER MANY PRODUCT-PROCESSES 

• OUR NORMAL ANALYSIS THAT COVERS AT LEAST EACH DIRECTLY 

REGULATED PRODUCT CAN NOT BE DONE 

INTERDEPENDENCE 

• THE CONCEPT OF CHEMICAL TREES IMPLIES COMPLEX INTERACTIONS 

AMONG REGULATED PRODUCTS 

• CUMULATIVE REGULATORY COSTS ARE BOTH IMPORTANT AND DIFFICULT 

TO ESTIMATE 

TIME 

• PRELIMINARY COSTS WILL NOT BE AVAILABLE UNTIL LATE DECEMBER 

• THE PRELIMINARY ECONOMIC ANALYSIS IS NEEDED BY LATE FEBRUARY 

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APPROACH FOR HON ECONOMIC ANALYSES 

CUMULATIVE COST 

• USE OF CHEMICAL TREES 

• BOTH AVERAGE AND HIGHER COST ESTIMATES 

SUBSET SELECTION FOR DETAILED ANALYSIS 

• CUMULATIVE COSTS WILL BE USED TO SELECT SOME PRODUCTS 

OF BOTH AVERAGE AND HIGHER CONTROL COSTS 

• WILL ALSO INCLUDE THE PRODUCTS FOR WHICH PRELIMINARY 

ANALYSIS WAS INITIATED UNDER THE OLD EFFORT 

SUBSET ANALYSIS 

• MARKET ANALYSIS PERFORMED FOR EACH PRODUCT CHOSEN ABOVE 

• THE RESULTS FOR THE WHOLE SET WILL BE USED TO ADDRESS 

POTENTIAL IMPACT FOR PRODUCTS NOT SELECTED FOR DETAILED 

ANALYSIS 

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