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OAR Box 1672 

Prepped by Charmelle Mathews 

Document Number: 

Docket Number: 

A-98-13 

Printed 9/30/2008 11:01:01 AM Sheet 62 of 132 
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HI PACIFIC ENVIRONMENTAL SERVICES. INC. 

Central Park West 

5001 South Miami Boulevard, Suite 300 

P.O. Box 12077 

Research Triangle Park, NC 27709-2077 

(919) 941-0333 

FAX (919) 941-0234 

FAX COMMUNICATION >^-333 

Date: 

July 1, 1998 

FROM: Bernd Haneke 

TO: Name: Michael Terraso 

AddreSS: Enron Corporation 

1400 Smith Street 

Houston, Texas 77002 

Phone Number: 713/ 853-6161 

FAX NUMBER: 713/ L%- T-A^** 

REFERENCE CODE: N812.001 

THIS COMMUNICATION COMPRISES 23 PAGES INCLUDING THIS PAGE. 

COMMENTS: 

As per our conversation, here is a copy of an identical letter which was 

sent to Mr. William Allison, Enron Liquids Pipeline Operating, PO Box 1188 

Houston, Texas 77251-1188. I have also enclosed a copy of the dated "return 

receipt letter" which we received from Enron. 

If we can be of further assistance, please do not hesitate to call myself or Mr. 

Steve Shedd (U.S. EPA) at 919/541-5397. 

WASHINGTON. O.C. • RESEARCH TRIANGLE PARK. NC • LOS ANGELES. CA • CINCINNATI. OH 
P.3 

IDENTICAL LETTER SIGNED BY MR. BRUCE JORDAN SENT TO MR. WILLIAM 

ALLISON ON MAY 4,1998 

^ 
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

§ SStTJ i? RESEARCH TRIANGLE PARK, NC 27711 

OFFICE OF 

AIR QUALITY PLANNING 

ANO STANDARDS 

Mr. William Allison 

Enron Liquids Pipeline Operating 

Post Office Box 1188 

Houston, Texas 77251-1188 

Dear Mr. Allison: 

The U.S. Environmental Protection Agency (EPA) is compiling detailed information on 

sources and quantities of hazardous air pollutant (HAP) emissions and control techniques. This 

information will be used in setting national emission standards for hazardous air pollutants 

(NESHAP) under section 112 of the Clean Air Act (CAA), as amended in 1990. The standards 

will apply to non-gasoline handling operations at both existing and new organic liquids 

distribution facilities. These standards are scheduled to be promulgated by November 2000. The 

EPA's initial steps for this endeavor include the collection of information on HAP emissions and 

emission reduction techniques in the organic liquids distribution industry. Your assistance in 

providing information is critical in developing a regulation that is realistic and workable, as well 

as protective of the environment. 

Enclosure 1 itemizes the information that you are requested to submit. The EPA will use 

the information to quantify HAP emissions; define the current status of emission control; and 

assess the environmental, energy, and economic impacts of installing and operating feasible 

emission control techniques. The information needed for regulatory development is contained in 

the information collection form approved by the Office of Management and Budget (OMB No. 

2060-0239). We are sensitive to the amount of labor required to respond to this request; 

therefore, to minimize demands on your time, information specific to the organic liquids 

distribution industry has been extracted from OMB form No. 2060-0239 and formatted to make 

it more relevant to this industry. The EPA consulted industry representatives from both organic 

liquids distribution companies and trade organizations, and their comments improved the 

instructions for this survey as well as its overall focus. Enclosure 1 is the reformatted version of 

the OMB approved form and contains detailed instructions. The OMB approved form is 

available upon request. 

The authority for the EPA's information gathering is included in section 114 ofthe CAA 

(42 U.S.C. 7414). Enclosure 2 contains a summary of this authority. You should also be aware 

that any failure to comply with our request is a violation of section 114 and as such is subject to 

3 
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enforcement under section 113 (specifically, section 113(d)(1)(B) ofthe CAA, which provides 

civil penalties of up to $25,000 per day of violation). If you believe that disclosure of any 

specific information that you submit would reveal a trade secret, clearly identify such 

information as discussed in the enclosure. Refer to enclosure 2 for the information the EPA may 

require, at a later time, to support your confidentiality claims. Any information determined to 

constitute a trade secret will be protected under 18 U.S.C. 1905. If no claim of confidentiality 

accompanies the information when it is received by the EPA, it may be made available to the 

public by the EPA without further notice (40 CFR part 2.203, September 1,1976). Section 114 

ofthe CAA exempts emission data from claims of confidentiality and emission data collected 

may be made available to the public. A clarification of what the EPA considers to be emission 

data is contained in enclosure 3. 

As noted in enclosure 4, we have designated Pacific Environmental Services, Inc. (PES) 

as an authorized representative ofthe EPA. Therefore, PES has the rights discussed above and in 

enclosure 2. As an authorized representative ofthe EPA, PES is subject to the provisions of 

42 U.S.C. 7414(c) respecting confidentiality of methods or processes entitled to protection as 

trade secrets. The PES contract with the EPA is No. 68D60013. 

Enclosure 5 summarizes Agency and Emission Standards Division policies and 

procedures for handling privileged information and describes EPA contractor commitments and 

procedures for use of confidential materials. It is the EPA's policy that compliance by an 

authorized representative with the requirements detailed in enclosure 5 provides sufficient 

protection for the rights of submitters of privileged information. 

We request that you return the completed information request by July 8,1998. If you 

have any questions regarding this request, please contact Mr. Stephen Shedd of my staff at 

(919) 541-5397, or E-mail address: shedd.steve@epa.gov. 

Sincerely, 

Bruce C. Jordan 

Director 

Emission Standards Division 

5 Enclosures 

< \ 
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SENDER: 

a Complete items 1 anchor 2 for additional services. 

•Complete Heme 3,4a, and 4b. 

• Print your name and address on tha raverae of thia form ao that wa can return thia 

card to you. 

•Attach thia form to tha front of the mailpiace, or on the back If apace does not 

pennit. 

•Write'Asfti/n Receipt Requested'on tha mailpiece below the article number. 

•The Return Receipt will show to whom the article waa delivered and the date 

delivered. 

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3. Article Addressed to: 

William Allison 

Enron Liquids Pipeline Operating 

Post Office Box 1188 

Houston, Texas 77251-1188 

4a. Article Number 

4b. Service Type 

D Registered B^rtified 

D Express Mail • Insured 

Bofutum Receipt for Merchancfise D COD 

7. Date of Delivery.. 

8. Addressee's Address (Only if requested 

and fee is paid) 

PS Form 102595-97.B-0179 Domesti c Retur n Receip t 

5 
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IDENTICAL LETTER WAS SENT TO MR. WILLIAM ALLISON ON JUNE 11,1998 

BUT RETURNED STAMPED "RETURNED TO SENDER, CANNOT LOCATE." 
P.8 

§ A \ 

Q 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

I XS&1 5 RESEARCH TRIANGLE PARK. NC 27711 

****? JUN 111998 

OFFICE OF 

- AIR QUALITY PLANNING 

AND STANDARDS 

Mr. Roderick Portine 

Liquid Distribution Manager 

Agway Petroleum Company 

Post Office Box 4852 

Syracuse, New York 13221-4852 

Dear Mr. Portine: 

The U.S. Environmental Protection Agency (EPA) is compiling detailed information on 

sources and quantities of hazardous air pollutant (HAP) emissions and control techniques from 

non-gasoline liquid handling operations at both existing and new organic liquids distribution 

facilities. This information will be used in setting national emission standards for hazardous air 

pollutants (NESHAP) under section 112 ofthe Clean Air Act (CAA), as amended in 1990. On 

April 29,1998,1 distributed an information collection request (ICR) survey to collect this 

information from your company and requested that the information be provided by July 8,1998. 

Since then, we have received industry requests for more time to complete and submit the ICR 

survey. This letter is to inform you of a change in the required due date for the ICR survey and to 

provide the Agency response to those industry requests. 

Many companies requested more time to complete this ICR survey, and some requesters 

noted the reasons for the need for additional time. They mentioned staff conflicts with upcoming 

work on SARA 313 reports and other MACT projects, and the complexity of some facilities and 

of the ICR survey itself. We are sensitive to the effort required to compile the survey 

information; therefore, to minimize demands on your time we consulted with industry 

representatives from both organic liquid distribution companies and trade organizations since the 

fall of 1997. Those discussions and reviews greatly improved the instructions for this ICR 

survey and its overall focus. Since release ofthe ICR survey, industry and the EPA identified 

and analyzed additional instructions intended to simplify, clarify, and reduce the data requested. 

Enclosed is a copy of those additional instructions. Additionally, the EPA and industry held a 

workshop to help improve the understanding and efficiency of this data collection. 

The EPA normally provides a 45-day response time for this type of ICR survey. We 

extended the due date to a total of 70 days (more than 2 months) to take into consideration that 

we were not sending the questionnaire directly to each facility. Industry requests have asked for 

additional time anywhere from one additional week to three additional months (total time of five 

RecycleeURecyclable . Printed with Vegetable Ol Based Inks on 100% Recycled Paper (40% Postconsumer) 

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months). As discussed above, the EPA believes that the Agency and industry have worked hard 

to focus and minimize the effort on this ICR survey and a long extension is not warranted. We 

do, however, agree with the need for some extension ofthe due date. Therefore, the EPA is now 

requesting that responses to the subject ICR survey be provided by August 17,1998. 

In discussions with many ofthe companies requesting additional time past the new 

August 17,1998 due date, many thought some additional time would still be necessary in 

extreme cases (as an example for large size chemical plants or refineries), while responses from 

their other facilities could be reported by August 17,1998. The EPA agrees with the requesters 

that additional time should be allowed, where warranted for extreme cases, if the responders 

meet the August 17,1998 due date for their other facilities and the additional requested time for 

these extreme cases is short (about a month). Additionally, the EPA requests that, before 

August 17,1998, respondents provide the rationale for additional time for the extreme case 

facility(s), a response delivery date, and identification ofthe facility(s). 

This letter and any additional information about this ICR survey will be available on the 

EPA's Internet site (www.epa.gov/ttn/oarpg/t3sp.html). Thank you for your present and future 

efforts in providing this information. Your assistance in this survey is critical in developing a 

regulation that is realistic and workable, as well as protective ofthe environment. 

If you have any questions on this ICR survey, please contact Mr. Stephen Shedd at 

(919) 541-5397, or E-mail address: shedd.steve@epa.gov. 

Sincerely, 

Bruce C. Jordan 

Director 

Emission Standards Division 

Enclosure 

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IDENTICAL LETTERS BEING SENT TO THE ADDRESSEES 

SEE ATTACHED 

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Mailing List for the Organic 

Liquids Distribution NESHAP 

Revised: June 11,1998 

Roderick Portine 

Liquid Distribution Manager 

Agway Petroleum Corporation 

Post Office Box 4852 

Syracuse, New York 13221-4852 

Kenneth J. TerBeek 

Manager, Env., Safety, Health 

and Reg. 

Aldrich Chemical Co., Inc. 

Post Office Box 355 

1001 W. St. Paul Avenue 

Milwaukee, Wisconsin 53233 

Rob Adams, Engineering 

Director 

Allied Energy Corporation 

2700 Ishkooda-Wenonah Road 

Birmingham, Alabama 35211-

5705 

Michael E. Law, President 

Allied Terminals, Inc. 

Post Office Box 717 

Norfolk, Virginia 23501 

Mr. Law 

L. Ray Taunton, 

Vice President of Operations 

Allied Signal, Inc. 

101 Columbia Road 

Post Office Box 1057 

Morristown, New Jersey 07962-

1057 

Jordan Jacobsen 

Alyeska Pipeline Service 

Company 

1835 South Bragaw Street 

Anchorage, Alaska 99512 

Robert F.Wright 

President and CEO 

Amerada Hess Corporation 

1185 Avenue ofthe Americas 

New York, New York 10036 

William Schneider, Envir./Safety 

Mgr. 

American Refining Group, Inc 

2010 William Pitt Way 

Pittsburgh, Pennsylvania 15238 

J.L. McGraw, Director 

Human Resources and 

Regulatory Affairs 

American Synthetic Rubber 

4500 Campground Road 

Post Office Box 32960 

Louisville, Kentucky 40232 

Alice Boomhower 

Amoco Chemical Company 

130 East Randolph Drive, P063 

Chicago, Illinois 60601 

Greg Skannal 

Amoco Pipeline Company 

28100 Torch Parkway, Suite 800 

Warrenville, Illinois 60555-4015 

Daniel T. Hisey, Vice President 

Corporate Center Environment, 

Health and Safety 

Atlantic Richfield Company 

444 South Flower Street 

Los Angeles, California 90071 

Richard Wright 

Ashland Chemical Company 

5200 Blazer Memorial Parkway 

Dublin, Ohio 43017 

Duane D. Gilliam, President 

Ashland Petroleum Company 

Post Office Box 391 

10 
P.12 

Ashland, Kentucky 41114 

Mr. Gilliam 

Tom Hmiel 

BASF Corporation 

3000 Continental Drive North 

Mt. Olive, New Jersey 07828-

1234 

L.P. Hughes 

Bayer Corporation 

100 Bayer Road 

Pittsburgh, Pennsylvania 15102 

Aake Gregertsen, President 

Baytank (Houston) Inc. 

12211 Port Road 

Seabrook, Texas 77586 

Kenneth Halligan 

Environmental Compliance 

Officer 

Borden & Remington Corp. 

106 Ferry Street 

Post Office Box 2573 

Fall River, Massachusetts 02722 

F.E. Mosier, President 

BP America Inc. 

200 Public Square, 5W 

Cleveland, Ohio 44114-2375 

Douglas A. Brown 

Brown Chemical Co., Inc. 

302 West Oakland Avenue 

Post Office Box 440 

Oakland, New Jersey 07436-

0440 

Patrick Castagna, President 

Carlos R. Leffler, Inc. 

Post Office Box 278 

Richland, Pennsylvania 17078-

0278 

Robert C. Oebser, Group VP 

CENEX 

Post Office Box 64089 

St. Paul, Minnesota 55164-0089 

Kenneth M. Jaggers 

Vice President, Compliance 

Chemcentral Corporation 

7050 W. 71st Street 

Post Office Box 730 

Bedford Park, Illinois 60499-

0730 

P.M. (Marty) Bitter 

Manager, Federal Relations 

Chevron Corporation 

Post Office Box 7753 

San Francisco, California 

94120-7753 H. Allen Greene

, General 

Manager 

Environmental and Regulatory 

Compliance 

CITGO Petroleum Corporation 

Post Office Box 3758 

Tulsa, Oklahoma 74102 ' 

Paul Melnuk, President & CEO 

Clark Refining & Marketing, Inc. 

8182 Maryland Avenue 

St. Louis, Missouri 63105 

Greg Walthers, Operations 

Manager 

Coastal Refining & Marketing 

Co. 

Coastal Tower 9 Greenway Plaza 

Houston, Texas 77046 

Don R. Brinkley, President & 

CEO 

Colonial Pipeline Company 

Post Office Box 18855 
P.13 

945 East Paces Ferry Road 

Atlanta, Georgia 30326 

Robert H. Demere, Jr., President 

Colonial Terminals, Inc. 

North Lathrop Avenue 

Post Office Box 576 

Savannah, Georgia 31402-0576 

Pat L. Jernigan 

CONDEA Vista Company 

Vice President, Operations 

Post Office Box 19029 

Houston, Texas 77224-9029 

Jeffrey S. Young, Operations 

Manager 

Continental Industrial Chemicals, 

Inc. 

5010 Hovis Road 

Charlotte, North Carolina 28208 

Richard J. Fitzgerald, Refineries 

Coordinator 

Conoco Inc. 

Post Office Box 2197 

Houston, Texas 77252 

Jim Doris, General Manager 

Croda Storage, Inc. 

534 South Front Street 

Elizabeth, New Jersey 07202 

W. L. Warnement, 

Environmental Safety Affairs 

Director 

Crown Central Petroleum 

Post Office Box 1759 

Houston, Texas 77251 

Olav S. Urheim, President 

Delaware Terminal Co. 

1050 Christina Avenue 

Wilmington, Delaware 19801 

Michael Suder, President 

Delta Commodities, Inc. 

3540 River Road 

Post Office Box 581 

Harvey, Louisiana 70059 

Mike Milan, Vice President 

Diamond Shamrock Ref. & 

Mktg. Co 

100 Northeast Loop 410 

San Antonio, Texas 78216 

Katherine M. Rhodes, 

Administrative Supervisor 

Dixie Pipeline Company 

1117 Perimeter Center 

Atlanta, Georgia 30338 

Maurice Gratton 

Dome Pipeline Corp. 

Amoco Canada Marketing Corp. 

1515 West 22nd Street 

Suite 801 

Oak Brook, Illinois 60521-2007 

Jackie Alderman 

The Dow Chemical Company 

2030 Willard H. Dow Center 

Midland, Michigan 48674 

John A. Dege, Manager-Air 

Programs 

Dupont Environmental 

Excellence Center 

1007 Market St., N2518-1 

Wilmington, Delaware 19898 

Richard C. Phelps 

Eastman Chemical Company 

Post Office Box 431 

Building 280W 

Kingsport, Tennessee 37662 

Donald C. Williams 

VP, Environmental and 

11 
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Regulatory Affairs 

Ellis & Everard (US Holdings) 

Inc. 

700 Galleria Parkway 

Suite 350 

Atlanta, Georgia 30339 

William Allison 

Enron Liquids Pipeline 

Operating 

Post Office Box 1188 

Houston, Texas 77251-1188 

Leslie B. Lampton, President 

Ergon, Inc. 

2829 Lakeland Drive 

Post Office Box 1639 

Jackson, Mississippi 39215-

1639 

Norman L. Morrow 

Exxon Chemical Americas 

13501 Katy Freeway 

Houston, Texas 77079-1398 

J. Schremp, President 

Firestone Synthetic Rubber & 

Latex 

381 West Wilbeth Road 

Post Office Box 26611 

Akron, Ohio 44319-0006 

G. T. Theriot, Manager 

Environmental and Safety 

Department 

Exxon Company, USA 

Post Office Box 2180 - Room 

4291 

Houston, Texas 77252-2180 

Brett A. Kriley, Environmental 

Health/Safety Manager 

Fina Oil and Chemical Company 

Post Office Box 2159 

Dallas, Texas 75221 

Tom O'Donnell, Branch 

Manager 

Fish-Callahan Chemical 

Company, Inc. 

18 Industrial Road 

Walpole, Massachusetts 02081 

CA. Bacon, President 

Fleet Supplies, Inc. 

Post Office Box 93831 

Cleveland, Ohio 44101-5831 

J. F. Chlebowski, President 

GATX Terminals Corporation 

500 West Monroe 

Chicago, Illinois 60661-3678 

Stephen V. Capone, 

Global Air Programs Leader 

GE Plastics 

One Plastics Avenue 

Pittsfield, Massachusetts 01201 

Thomas G. Swanson, Vice 

President 

Georgia Gulf Corporation 

400 Perimeter Center Terrace 

Box 105197 

Atlanta, Georgia 30348 

Robert W. Milk, Exec. Vice 

President 

The Goodyear Tire and Rubber 

Co. 

1144 East Market Street 

Akron, Ohio 44316 

Robert M. Gordon, Jr., President 

Gordon Terminal Service 

Company 

Post Office Box 313 

McKees Rocks, Pennsylvania 

15136 

George A. Vincent 

0 
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President and CEO 

The CP. Hall Company 

311 South Wacker Drive 

Suite 4700 

Chicago, Illinois 60606-6622 

Blake Tucker 

HCl Chemtech Distribution, Inc. 

424 South Woods Mill Road, 

Suite 325 

Chesterfield, Missouri 63017 

Anne Conley-Pitchell 

Legal Department 

Hoescht-Celanese Chemical 

Group 

30 Independence Boulevard 

Post Office Box 4415 

Warren, New Jersey 07060-4915 

Jeffrey J. Simko 

Corporate Environmental 

Manager 

Holland Chemical International 

(HCl) 

1551 N. Tustin Avenue, Suite 

430 

Santa Ana, California 92705-

8638 

Bryon K. Fortney, Manager 

Hollywood Marine Inc. 

55 Waugh Drive 

Post Officest Office Box 1343 

Houston, Texas 77251 

Joseph A. Lima, Vice President 

Houghton Chemical Corporation 

Post Office Box 307 

52 Cambridge Street 

Allston, Massachusetts 02134 

Jon M. Huntsman, Chairman and 

CEO 

Huntsman Corporation 

500 Huntsman Way 

Salt Lake City, Utah 84108 

Charles Miller Smith, President 

and CEO 

ICI Americas, Inc. 

3411 Siverside Road 

Wilmington, Delaware 19897-

0001 

Joel Fazzio 

International-Matex Tank 

Terminals 

321 St. Charles Avenue, 3d Floor 

Suite 

New Orleans, Louisiana 70130 

Herman Luffinan, Chairman, 

CEO 

Independent Terminal & Pipeline 

Company 

(ITAPCO) 

530 Wells Fargo Drive, Suite 108 

Houston, Texas 77090 

Stephen W. Miles, President 

Intercontinental Terminals 

Company 

17 Briar Hollow, Suite 402 

Houston, Texas 77027-2896 

John L. MacDonald 

JLM Chemicals, Inc. 

8675 Hidden River Parkway 

Tampa, Florida 33637 

Leon E. Hutchens, President 

Kaneb Pipe Line Company 

100 North Broadway, Suite 550 

Wichita, Kansas 67202 

J. M. Ehlen 

Koch Refining Company 

Post Office Box 1478 

Houston, Texas 77251-1478 

\A 
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•. 

CS. Nobles 

Koch Chemical Company 

Post Office Box 1478 

Houston, Texas 77251-1478 

Glenn Gibisch, President 

Lake River Corporation 

5005 South Harlem Avenue 

Forest View, Illinois 60402 

Ronald Espalin, VP of 

Operations 

Los Angeles Chemical 

Corporation 

4545 Ardine Street 

Post Office Box 1987 

South Gate, California 90280 

Dave Cady, President 

Louis Dreyfus Energy Corp. 

Post Office Box 76045 

Atlanta, Georgia 30358-1045 

Kenneth E. Lowe, Jr., Vice 

President 

Lowe Chemical Company 

8300 Baker Avenue 

Cleveland, Ohio 44102 

Charles M. Rampacek, President 

Lyondell - CITGO Refining Co. 

Post Office Box 2451 

Houston, Texas 77252-2451 

Gary Wilson 

Marathon Oil Company 

539 South Main Street 

Findlay,Ohio 45840 

John Burns, President 

Maritank Inc. 

67th Street at the Schuylkill 

River 

Philadelphia, Pennsylvania 

19153 

R. G. Butler 

Mid-Continent Pipeline 

Company 

Post Office Box 2039 

Tulsa, Oklahoma 74102-2039 

Motoo Hayashi, Sr. VP 

Mitsubishi International 

Corporation 

520 Madison Avenue 

18th Floor 

New York, New York 10022 

Yuji Takagi, General Manager 

Mitsui & Company 

200 Park Avenue 

New York, New York 10166-

0130 

W. R. Beck 

Mobil Oil Corporation 

3225 Gallows Road 

Fairfax, Virginia 22037-0001 

t

 Joseph D. Crowley, President 

New Haven Terminal, Inc. 

100 Waterfront Street 

Post Office Box 9423 

New Haven, Connecticut 06534 

Donald F. Newman, Chairman 

NOCO Energy Corp. 

700 Grand Island Boulevard 

Post Office Box 86 

Tonawanda, New York 14151-

0086 

Mr. Newman 

Lloyd G. Hansen, President 

Nordix Incorporated of Louisiana 

768 Eventide Drive 

Memphis, Tennessee 38120 

Nik Mukhopadhyay, Manager 

Occidental Chemical Corporation 

15 
P.17 

Post Office Box 809050 

Dallas, Texas 75380-9050 

Adrian P. de Monchy, President 

Oiltanking Houston, Inc. 

15602 Jacintoport Boulevard 

Post Office Box 96290 

Houston, Texas 77213-6290 

Roy E. Wansik, President 

Paktank Corporation 

Suite 2200 

2000 West Loop South 

Houston, Texas 77027-3597 

Michael L. Rose, Senior Vice 

President 

Peerless Oil & Chemicals, Inc. 

666 Third Avenue, 30th Floor 

New York, New York 10017 

James J. Keating, President 

Petro-Diamond Terminal 

Company 

1920 Lugger Way 

Long Beach, California 90813-

2634 

Richard C Nelson, President 

PetroUnited Terminals, Inc. 

Suite 4300 

333 Clay Street 

Houston, Texas 77002 

David T. Emery 

Health, Environment & Safety 

Phillips Petroleum Company 

12A2 Phillips Building 

Bartlesville, Oklahoma 74004 

George Coiner 

Plains Marketing and 

Transportation Inc. 

1600 Smith Street, Suite 1300 

Houston, Texas 77002 

CA. Lorelli, General Counsel 

and Secretary 

Reichhold Chemicals, Inc. 

Post Office Box 13582 

Research Triangle Park, North 

Carolina 27709-3582 

Robert E. Lee, President 

River Transportation Company 

5297 River Road 

Post Office Box 33041 

Cincinnati, Ohio 45233 

John P. Mulroney, President 

Rohm and Haas Company 

100 Independence Mall West 

Philadelphia, Pennsylvania 

19106-2399 

Nat Rowell, President 

Rowell Chemical Corporation 

15 Salt Creek Lane, Suite 205 

Hinsdale, Illinois 60521 

Mr. Rowell 

F.A. Troups, Engineering 

Manager 

Rubicon, Inc. 

Post Office Box 517 

Geismar, Louisiana 70734 

Jack McClure 

Shell Chemical 

Post Office Box 2099 

Houston, Texas 77210 

C W. Fink 

Sinclair Oil Corporation 

Post Office Box 30825 

Salt Lake City, Utah 84130-

0825 

Glen Slay, Vice President 

Slay Bulk Terminals 

1441 Hampton Avenue 

Ib 
P.18 

Post Office Box 39904 

St. Louis, Missouri 63139 

Peter B. Ramaley 

Director of Regulatory Affairs 

SOCO Chemical, Inc. 

Post Office Box 13786 

Reading, Pennsylvania 19612-

3786 

Dave Krawczyk 

Solutia, Inc. 

10300 Olive Boulevard (Mail 

Code F2EP) 

St. Louis, Missouri 63166-6760 

Robert S. English, President 

Solutions 

(Chemical Solutions, Inc.) 

Post Office Box 675 

Franklin, Massachusetts 

Jordi Baizan, Vice President 

Solvents & Chemicals, Inc. 

Post Office Box 490 

Pearland, Texas 77588 

Craig A. Overstreet, President 

South Coast Terminals, Inc. 

Post Office Box 15535 

Houston, Texas 77220-5535 

Paul T. Owens, President 

Southside River-Rail Terminal, 

Inc. 

3500 Southside Avenue 

Cincinnati, Ohio 45204 

Charles F. Hamilton 

Manager-Regulatory Affairs 

Southwest Solvents & Chemicals 

Post Office Box 41065 

Houston, Texas 77241 

Robert J. Nicholson, Jr. 

Operations Manager 

Specialty Chemical Co., Inc. 

Post Office Box 2606 

2018 King Edward Avenue 

Cleveland, Tennessee 37320 

Jesse M. Gray 

General Manager 

Star Enterprise/Texaco 

12700 Northborough Drive 

Houston, Texas 77067-2508 

James G. Cameron, President 

Statia Terminals Southwest, Inc. 

c/o Statia Terminals, Inc. 

800 Fairway Drive, Suite 295 

Deerfield Beach, Florida 33441 

Genarro Dessy, President 

Demaco Corporation 

Post Office Box 8283 

Ponce, Puerto Rico 00732 

J. Virgil Waggoner, President 

and CEO 

Sterling Chemicals, Inc. 

1200 Smith Street, Suite 1900 

Houston, Texas 77002-4312 

Jacob Bothel Stolt-Nielsen, III 

Stolt-Nielsen Inc. 

15602 Jacintoport Boulevard 

Post Office Box 96438 

Houston, Texas 77213-6438 

Frank M. Gilbert 

Stratus Petroleum Corporation 

9040 Roswell Road, Suite 380 

Atlanta, Georgia 30350 

Newell Baker, Chairman ofthe 

Board 

Streett, J.D. & Company, Inc. 

144 Weldon Parkway 

Maryland Heights, Missouri 

11 
P.19 

63043 

Patrick E. Coggins, Senior Vice 

President, 

Environmental and Public 

Affairs 

Sun Refining & Marketing Co. 

1801 Market Street, 25th Floor 

Philadelphia, Pennsylvania 

19103-1699 

Raymond J. Roembke, Jr. 

Superior Solvents and Chemicals 

400 West Regent Street 

Indianapolis, Indiana 46225 

Fred T. Johnson, President 

Support Terminal Services, Inc. 

17304 Preston Road, Suite 1000 

Dallas Texas 75252-5623 

William L. Thacker, President 

and CEO 

TEPPCO 

Post Office Box 2521 

Houston, Texas 77252-2521 

R.G. Brown, General Manager 

Texaco Chemical Company 

3040 Post Oak Boulevard 

Post Office Box 27707 (77227-

7707) 

Houston, Texas 77056 

Bill Waycaster, President & CEO 

Texas Petrochemical 

Corporation 

3 Riverway, Suite 1500 

Houston, Texas 77056 

Wesley Hickey, President & 

CEO 

Tidewater Terminal Company 

Post Office Box 1210 

Vancouver, Washington 98666 

Gene C. Gradick, President 

Tonkawa Gas Processing 

Company 

Fist City Center 

1700 Pacific Avenue 

Dallas, Texas 75201-4696 

Kevin E. Brown, Air/Regulatory 

Compliance Mgr. 

Transmontaigne Transp. Services 

Post Office Box 1503 

Fayetteville, Arkansas 72702 

Mr. Brown 

Edward M. Pitkin, President 

Ulrich Chemical, Inc. 

3111 North Post Road 

Indianapolis, Indiana 46226 

Newton W. Wilson, President 

Union Texas Petrochemicals 

Post Office Box 2120 

Houston, Texas 77252-2120 

John Soice 

Air Issues Manager 

Union Carbide Corporation 

Building 2000/Rm 3426 

Post Office Box 8361 

South Charleston, West Virginia 

25303 

William A. Butler 

Senior VP and General Counsel 

Van Waters & Rogers Inc. 

Post Office Box 34325 

Seattle, Washington 98124-1325 

Baines Manning 

Valero Refining & Marketing 

Company 

Post Office Box 53720 

Houston, Texas 77052-3720 

William L. Whitcher, President 

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P.20 

Viking Chemical Company 

Post Office Box 1595 

Rockford, Illinois 61110 

Rebecca A. Munro, President 

Vulcan, Inc. 

7 Circle Road 

Darien, Connecticut 06820 

Sande Wische, President 

W.A.S. Terminals Corporation 

126 Passaic Street 

Newark, New Jersey 07104 

William A. Zartler 

Vice President and General 

Manager 

Warren Petroleum Company, 

L.P. 

1000 Louisiana, Suite 

5800Houston, Texas 77002 

Fred Jones, Vice President 

Westlake Petrochemicals 

Corporation 

Westlake Center 

2801 Post Oak Boulevard 

Houston, Texas 77056 

James R. Lacy, Executive VP 

Westway Terminal Company 

365 Canal Street, Suite 2200 

New Orleans, Louisiana 70130-

1134 

Steve Cropper, President and 

CEO 

Williams Pipe Line Company 

Post Office Box 3448 

Tulsa, Oklahoma 74101 

Garland Middendorf, Owner 

Wolf Lake Terminals 

Post Office Box 565 

3200 Sheffield 

Hammond, Indiana 46320 

Colie B. Whitaker, Jr., Chairman 

Whitaker Oil Company 

1557 Marietta Road, N.W. 

Atlanta, Georgia 30377 

Richard Shore, Vice President 

Wickland Oil Terminals 

90 San Pablo Avenue 

Crockett, California 94525 
P.21 

May 22, 1998 

Additions to instructions for: 

INDUSTRY-SPECIFIC INFORMATION COLLECTION REQUEST 

FOR THE DEVELOPMENT OF AN 

ORGANIC LIQUIDS DISTRIBUTION 

MAXIMUM ACHIEVABLE CONTROL TECHNOLOGY (MACT) STANDARD 

(Originally Mailed: April 29,1998) 

I. INSTRUCTIONS 

add the following to the instructions: 

K. What information must be provided for sources covered by other MACT standards not 

listed earlier? 

Several recipients ofthe subject ICR have asked if distribution equipment is to be surveyed 

that are subject to another final, proposed, or draft MACT standard. As stated before, the intent 

ofthe Organic Liquids Distribution MACT survey is to not overlap the emission point sources 

regulated under another MACT'. Below are some additional instructions on this question. 

1. Final MACT Standards. The instructions provide allowances to exclude distribution point 

emission source equipment covered by listed final MACT standards and provide special 

instructions for them. Those listed MACT standards include: the Hazardous Organic NESHAP 

(HON), Gasoline Distribution, Marine Vessel Loading, and Refinery MACT. Callers have asked 

if EPA should include all final MACT standards in that list and they have cited the final MACT 

standards for Polymers and Resins 1, 2, and 4 as an example of additional overlapping standards. 

The Polymers and Resins final MACT standards are similar in structure to how the HON and the 

Refinery MACT regulate equipment. As discussed in subsections E and F ofthe original 

instructions, these MACTs cover storage vessels and loading racks based on predominant or 

exclusive use with a regulated chemical or refinery process unit. Thus, because it is a site and 

process specific determination, these instructions cannot be clarified more specifically. There 

may be other final MACT standards that overlap this survey that are not identified above that 

have similar language or determinations. For this survey, respondents may exclude distribution 

storage vessels, loading racks, and loading arms clearly regulated under ajjy final MACT 

standard if the respondent identifies the equipment as follows: 

On the plot plan2 requested in subsection A of Section III ofthe original 

instructions, show which storage vessels and loading arms and racks are regulated 

under a final MACT and which are not, and identify the MACT standard on each 

1 

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P.22 

May 22, 1998 

piece of equipment. "Regulated" vessels, loading arms, and racks can include those 

that are otherwise subject to the MACT, but do not need to be controlled because 

they do not meet the control criteria (small tank, below HAP applicability limits or 

vapor pressure exemptions in Marine Vessel MACT, etc.) given in the subject MACT. 

2. Non-Final MACT Standards. For MACT standards that are not final standards, the respondent 

must have clear knowledge and support that a non-final MACT standard will regulate the 

associated distribution equipment. Some non-final MACT standards have similar HON 

regulatory structure as discussed above in subsection K.1, and determinations will be site 

specific. Additionally, some non-final MACT standards are not regulating some distribution 

emission sources. As an example, the proposed MACT for Pesticides and the MACT under 

development for Miscellaneous Organic NESHAP (MON) do not regulate loading racks or arms, 

nor were they surveyed under those projects. Therefore, those loading racks and arms not 

covered under those MACTs must be surveyed in this OLD survey3. In conclusion, respondents 

may exclude distribution storage vessels, loading racks, and loading arms clearly regulated under 

any non-final MACT standard if the equipment is identified below. Publicly available written 

information must support this determination. 

On the plot plan2 requested in subsection A of Section III ofthe original 

instructions, show which storage vessels and loading arms and racks are regulated 

under a non-final MACT and which are not, and identify the MACT standard on 

each piece of equipment. "Regulated" vessels, loading arms, and racks can include 

those that are otherwise subject to the MACT, but do not need to be controlled 

because they do not meet the control criteria (small tank, below HAP applicability 

limits or vapor pressure exemptions in Marine Vessel MACT, etc.) given in the 

subject non-final MACTL. What information must be provided for plant sites with all distribution equipment 

completely covered bv other MACT standards? 

Several recipients ofthe subject ICR have asked if plant sites that have all distribution equipment 

completely covered by other MACT standards, do they still need to submit a plot plan? This 

situation was anticipated for bulk gasoline terminals, but not for others. Bulk gasoline terminals 

are allowed to not submit a plot plan or other data if they only handle gasoline or other nonsurveyed organic liquids. EPA does not need plot plans of any plant site where all distribution 

equipment is covered by other MACT standards. However, if the company does not have any 

plant sites to report data on, then respondents must report this finding in writing to the EPA at 

the address shown in subsection J of this section. 

t\ 
May 22,1998 

M. Can anv type of process or facility with the SIC codes listed in Section I. subsection H 

be excluded from this survey? 

Several recipients ofthe subject ICR have asked whether any plant sites or processes that have 

the SIC codes listed in Section I. subsection H have to submit a survey response. The text of 

that subsection presents this exclusion for compounding, blending, and packaging facilities. The 

EPA intended this subsection to provide an exclusion for small compounding, blending, and 

package facilities that may be subject to the MON standards. We did not intend this exclusion to 

apply to chemical processing plants and processes, etc., as had callers had hoped. The purpose of 

this paragraph is to clarify this intent and use, and to announce that the provision (Section I, 

subsection ID is now unnecessary because Section I. subsections K and L ofthe above new 

instructions, exclude affected MON equipment. 

1. MACT used in this survey means Maximum Achievable Control Technology standards set under 

section 112(d) ofthe Clean Air Act as amended in 1990 (the Act). We codify MACT standards in Title 

40, Part 63 ofthe Code of Federal Regulations. Recipients ofthe subject ICR have asked if equipment 

controlled by other non-MACT air standards, in particular those hazardous air pollutant standards under 

Part 61 (ex. Benzene Waste), can be excluded from a detailed response to this survey? Since those rules 

are under different provisions ofthe Act or for the example, prior amendments, this equipment must be 

included in the detailed response so that a decision can be made based on the MACT provisions in the 

Act. However, many MACT standards specify Part 61 or 60 (NSPS) standards as an alternative or 

equivalent to MACT. In these cases, the MACT standard that uses the Part 60 or 63 standard should be 

cited in this survey. 

2. Plot Plans: The detailed plot plans that the survey requests here and all subsections ofthe section 

and in subsection A of Section III are requested for areas ofthe plant site where organic liquid 

distribution sources and control equipment are to be surveyed. The survey also requires a general plot 

plan that provides an understanding ofthe general layout and operation ofthe plant site, and shows the 

areas ofthe plant site where organic liquid distribution sources and control equipment will be surveyed. 

This survey is also asking respondents to show where other MACT standards control organic liquid 

distribution sources and control equipment. In these cases, respondents must show and include 

distribution equipment controlled by other MACT standards on the detailed plot plan to the degree 

necessary to show interconnected equipment. On the general plot plan, the distribution equipment 

controlled by other MACT standards should be presented in a general nature as needed to provide a 

general understanding ofthe layout and operation ofthe plant site. 

3. Note that although these sources may be surveyed under the OLD project, the EPA has not made a 

decision as to whether to add these sources now or later to the subject non-final standard or include under 

the OLD standard. As with refinery gasoline loading racks and distribution storage vessels, the Gasoline 

Distribution MACT promulgated standards for those sources, and then EPA opted to later move the 

requirements under the Refinery MACT to cover those refinery sources under one standard to ease 

^ 
implementation and compliance. 

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May 22. 1998