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OAR Box 1875 

Prepped by Ollie Stewart 

Document Number: 

6) ll-E-24 

Docket Number: 

A-90-19 

Printed 12/1/2008 11:12:44 AM Sheet 6 of 86 
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f RADIAN 

A-90-19 

ll-E-24 

MEETING NOTES 

DATE: April 2, 1991 

PLACE: Mutual Building, Durham, North Carolina 

ATTENDEES: DEC l8 

II 

Elaine Manning, U.S. EPA, CPB 

Penny Lassiter, U.S. EPA, CPB 

Debbie Stackhouse, U.S. EPA, SDB 

Susan Vyatt, U.S. EPA, CPB 

Bob Lucas, U.S. EPA, CPB 

K.C. Hustvedt, U.S. EPA, CPB 

Bob Rosensteel, U.S. EPA, CPB 

Michele Aston, U.S. EPA, CPB 

Martha Smith, U.S. EPA 

David Misenheimer, U.S. EPA, EIB/TSD 

Mary Ann Stewart, U.S. EPA, EIB/TSD 

Annette Stanley, Chemical 

Manufacturer's Association (CMA) 

Nancy Cookson, CMA 

Graham Fitzsimons, Research Triangle; 

Institute (RTI)

 l' 

Marvin Branscome, RTI 

Clark Allen, RTI 

Joe Trombka, Dow Chemical 

Alan Roy, Allied-Signal 

Jerry M. Schroy, Monsanto Co. 

Gordon Brown, Exxon Chemical 

Lew Buchanan, Atochem North America 

Jeff Elliott, Radian Corporation 

Ron Berglund, Union Carbide 

Paul Jann, Ou Pont Co. 

SUBJECT: HON Wastewater Regulation 

PURPOSE OF MEETING 

Representatives of the Chemical Manufacturer's Association -

(CMA) requested to meet with the Environmental Protection 

Agency's (EPA's) Office of Air Quality Planning and Standards 

(OAQPS) to discuss the Hazardous Organic NESHAP (HON) being 

developed to regulate emissions from wastewater. 

Applicability of Regulation 

Paul Jann, the spokesperson for the secondary emissions 

committee within CMA, raised a question concerning applicability. 

The concern was that if MACT is triggered for vents within a 

process unit, would this automatically trigger wastewater 

requirements for MACT controls as well. Bob Rosensteel responded 

by saying that applicability for the individual sources would be 

determined individually and triggering control requirements for 

process vents would not trigger control requirements for 

wastewater. 

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Low Volatility Compounds 

Concerns were also raised by Paul Jann about EPA requiring 

treatment by steam stripping of low volatility compounds. Paul 

Jann suggested a tiered Henry's Law approach with concentration 

cutoffs of 500, 100, and 10 for low, medium, and high volatility 

compounds. With volatility measured by Henry's Law, low 

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volatility compounds would be approximately 10 , medium 

volatility would be 10' , and high volatility would be IO*3. 

Penny Lassiter responded that the regulation will have flow and 

concentration cutoffs and will account for volatility. One of 

the ways in which the regulation will account for volatility is 

through the use of Method 25D. CMA expressed concerns regarding 

the use of Method 25D since they feel it is too "robust" a 

method. CMA requested that any control requirements allow 

maximum flexibility (i.e., steam stripper or equivalent should 

allow maximum flexibility to meet the or equivalent standard). 

Gordon Brown asked if there was a possibility that low 

Henry's Law compounds may be exempted from control requirements 

for wastewater. Penny Lassiter and K.C. Hustvedt stated that 

there was a possibility that this might be incorporated into the 

standard. 

Mass per Year Cutoff 

Paul Jann asked is if there would be a mass per year cutoff 

like in the Benzene NESHAP. K.C. Hustvedt responded that there 

may be a mass per year cutoff on a facility basis, however, it 

would not be like the Benzene mass per year cutoff. 

Point of Generation 

There was some discussion regarding definition of point-ofgeneration. The general conclusion was that the final definition 

could not be provided at this time, however, a general definition 

would be based on the fact that the point-of-generation must be 

prior to any point of potential emissions from the wastewater. 

CMA requested that there be allowances for enclosing a sewer 

system rather than hard piping to the control device. Debbie 

Stackhouse responded that there would probably be some provision 

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as there was in the Benzene Waste Standard which would allow 

enclosure of the sewer system as a means of transport to the 

control device. 

Penny Lassiter responded to several questions regarding 

format of the standard by saying that two large issues are yet to 

be resolved and until these issues are resolved, progress on 

development of format of the standard is being slowed. These 

issues are the MACT floors and risk issues. 

Wastewater Models 

CMA recommended that we should develop a couple of good 

databases that are reliable and have been QA/QC'd, that can be 

used for model validation. SIMS was developed as a simple tool 

for states doing area-wide emissions inventories; it was not 

intended for source-specific detail, like CHEMDAT. CMA pointed 

out that although SIMS and CHEMDAT should yield the same answers, 

industry was having some problem with this. CMA requested that 

there be some qualification of the use of defaults. CMA also 

mentioned that they have developed the PAVE model, and commented 

that this has a more detailed, accurate representation of 

biodegradation. 

Equipment Supply 

CMA repeated their assertion stated in a previous meeting 

with EPA that there will be a problem with vendors being able to 

supply equipment in time for industry to meet the compliance 

dates. CMA would prefer a staggered compliance schedule. 

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