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OAR Box 1875 

Prepped by Ollie Stewart 

Document Number: 

42) ll-E-60 

Docket Number: 

A-90-19 

Printed 12/1/200811:12:46 AM Sheet 42 of 86 
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A-90-19 

ll-E-60 

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SB 

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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

Office of Air Quality Planning and Standards ' "£•'-"•;•*-...^ 

Research Triangle Park, North Carolina 27711 ''' :fX^i ff! ~fi 0) 

DEC 2 4 1992 DEC n 1992 

MEMORANDUM 

SUBJECT: 

FROM: 

TO: 

CMA and EPA/ESD Meeting of April 14, 1992 on Clarity of 

the 12/91 Draft Proposal Package for the Hazardous 

Organic NESHAP (HON) 

V

m

Janet S. Meyer T^ 

Standards Development Branch, ESD (MD-13) 

Docket A-90-19, Hazardous Organic NESHAP: 

General Information and Process Vents 

I. Purpose 

Representatives of the Environmental Protection Agency's 

(EPA's) Emission Standards Division (ESD) met with the Chemical 

Manufacturers Association (CMA) to discuss their concerns with 

the draft proposal HON package. The objectives of the discussion 

were to determine if CMA's concerns resulted from a lack of 

clarity in the draft rule, lack of explanation of factors 

considered, or if additional information would help resolve the 

concern. 

II. Place and Date of Meeting 

OMNI Hotel 

Durham, NC 

8:00 a.m. - 4:00 p.m. 

Ill, 

April 14, 1992 

Attendees 

Name 

Jan Meyer 

Amy Meyers 

Joe Hovious 

David Gustafson 

John Dege 

Norm Morrow 

Joe Woolbert 

Annette Stanley 

Kathy Bailey 

Organization 

EPA/SDB 

CMA 

Union Carbide 

DOW 

DuPont 

Exxon Chemicals 

Eastman Chemical 

CMA 

CMA 

Phone # 

919 

202 

203 

517 

302 

504 

903 

202 

202 

541-5254 

887-1370 

794-5183 

636-2953 

773-4229 

359-7226 

237-5475 

887-1103 

887-1186 
P.3 

Name Organization Phone # 

Gary O'Dea CMA 202 887-1353 

Vivian Mclntire Eastman Chemical 615 229-3045 

Daphne McMurrer SDB/EPA 919 541-0248 

Chuck Malloch Monsanto 314 694-8889 

Brian Taranto Exxon Chemical 713 870-6117 

Valerie Everette Radian 919 541-9100 

Julie Anne Probert Radian 919 541-9100 

Ruth Mead Radian 919 541-9100 

Bob Rosensteel CPB/EPA 919 541-5608 

Dave Markwordt CPB/EPA 919 541-0835 

IV. Discussion 

This meeting's discussions were a continuation of the 

February 27, 1992 discussion on CMA concerns regarding the draft 

proposal package. The discussion topics are listed in the 

meeting agenda, which is provided in Attachment 1. These 

discussions are summarized below by major topic area. 

Implementation Plan 

The CMA expressed concerns that the implementation plan was 

duplicative with the operating permit application. Attachment 2 

contains the summary comparison provided by CMA to illustrate the 

overlap of the provisions. The CMA representatives also 

expressed concerns with the amount of detailed information that 

would have to be submitted 120 days after the final rule was 

issued. Their interpretation of the draft requirements was that 

they would have to provide detailed information on whether an 

emission point was subject to control and the planned controls 

within 120 days. The final concern expressed was that, as 

drafted, the implementation plan would be enforcable before the 

compliance date (see p.312 of 12/91 draft). 

The EPA representatives explained that the implementation 

plan was included for three basic purposes. First, EPA Regions 

and the States need to know which sources are subject and how 

many of the emission points in the source will be subject to the 

rule. This information was believed necessary to provide 

information needed for program planning. Second, there was a 

concern that there would be a gap between the expected compliance 

date and startup of permit programs. The implementation plan was 

designed to provide an enforceable commitment for each point 

subject to the HON should there not be an operating permit for 

the source. Third, there was a concern that the permit plan may 

not contain enough detailed information to document the validity 

of the proposed emission averaging balance. It was never 

intended that the implementation plan be enforceable before the 

compliance date or that a source could not revise the plan to 

reflect the best available information. 
P.4 

The discussion focused on developing alternative approaches 

to providing the necessary information for enforcement, while 

minimizing duplicative reporting requirements. The EPA agreed to 

consider replacing the draft requirements for an initial simple 

notice at 90 to 120 days after the rule's effective date and to 

only require the implementation plan in cases where there is no 

permit program. This alternative approach was believed to 

provide the information needed for program planning and to avoid 

unnecessary paperwork. It was noted that: (1) these changes 

would have to be approved by senior management and (2) we were 

seeking the Regions' views on the types of information on the 

sources that the Regions need early. 

Recordkeeping and Reporting 

The EPA provided a summary of the recordkeeping and 

reporting requirements in Subpart G for use in this discussion. 

The summary is included in Attachment 3. The summary was 

prepared as part of a review of all the provisions to check for 

inconsistencies, omissions, unnecessary reports, and 

duplications. As part of the description of the summary tables, 

EPA explained changes that would be made to correct problems 

discovered in the draft rule. The summary was also used as a 

means of identifying major items of concern to CMA. 

Suggestions for ways to reduce the burden of the reporting 

requirements that were discussed included: (1) use semiannual 

reporting; (2) base the reporting frequency on the performance of 

the source—reward better-performing sources with less frequent 

reporting; and (3) no reporting unless the permit authority 

requests it. The EPA agreed to discuss these ideas with the Work 

Group and get back to CMA with the reaction. The CMA agreed to 

investigate timeframes for preparing test reports and to provide 

information on reasonable timeframes for submitting reports. 

Process Vents 

Topics discussed regarding the draft provisions for process 

vents were: 

1. Calculation of the total resource efficiency (TRE) index 

for all combinations of vents in a process unit; 

2. Requirement to determine TRE for vents that are (or will 

be) controlled by a 98% efficient combustor; and 

3. Allowing use of engineering assessment of TRE parameter 

information in lieu of test data in some cases. 
P.5 

The first two topics had been discussed in the February 27, 

1992 meeting with CMA. The idea of removing the requirement to 

calculate TRE for all combinations of vents has been discussed 

with EPA management, but no decision has been made at this time. 

Considering the potential safety problems and the increased 

paperwork burden, ESD staff have recommended to senior management 

that this requirement be dropped. The ESD staff agreed that TRE 

determinations are not necessary in instances where a vent is 

controlled using a 98% efficient combustor. The draft rule 

inadvertently failed to allow a source to comply directly without 

performing a TRE determination. It was agreed that language 

would be added to the draft rule to correct this oversight. 

Engineering assessment of TRE (topic 3) was suggested as a 

means of reducing the burden of the test requirements in cases 

where very high TRE values are expected. The CMA suggested that 

calculation at maximum conditions that would result in the lowest 

TRE value be allowed and testing to determine the input values 

for the TRE equation should be reserved for intermediate cases 

between TRE of 1 and some high value (e.g., 4 or 8). In their 

opinion, it is not necessary to have as precise information for 

very high TRE values as it is in cases where the TRE is close to 

1. The ESD staff agreed to evaluate this suggestion and get back 

to CMA. As part of this evaluation, ESD agreed to review 

possible reasons this approach was not taken with the new source 

performance standard and to review the variability of the test 

data used in the TRE equation. 

Attachment 4 presents CMA's suggested clarifications to 

monitoring provisions for vents. The attachment includes 

clarifying language for monitoring provisions in cases where a 

TRE is maintained above 1 by a means other than a recovery 

device. Attachment 4 also includes suggested editorial changes 

to language regarding by-pass lines to clarify that drains and 

bleeds are not process vents. 

Emissions Averaging 

The discussion focused on the two critical concerns to CMA: 

(1) quarterly averages based on actual emissions; and (2) no 

credit for controls in place before promulgation of the rule, 

except for 33/50 pollution prevention measures and Early 

Reduction. These concerns are the same concerns raised in the 

February 27, 1992 meeting. 

Actual vs. allowable. The ESD staff explained the rationale 

for the policy position taken on actual versus allowable 

emissions using the example in Attachment 5. The CMA view was 

that regardless of those considerations, quarterly rolling 

averages based on actual emissions were unworkable. The tradeoffs between the alternatives of short-term allowable and long-
P.6 

term actual emissions were discussed, but no alternative 

solutions that satisfied both paries goals were identified. 

Credit for overcontrol. The CMA believes that the position 

taken in the draft proposal package sends the wrong message and 

that EPA needs to reassess the effect of this position on the 

overall goal of emission reductions. The EPA requested that CMA 

provide information on the number of controlled Group 2 points to 

get a sense of the magnitude of the credits for existing 

controls. Information available to EPA suggests that the 

potential credit is small and data on the magnitude of this 

potential credit and the nature of the controlled points would be 

helpful for resolving this issue. 

During this discussion CMA requested clarification of the 

type actions that would be creditable as a pollution prevention 

measure. The ESD staff said that they would try to provide some 

specific guidance on what is a pollution prevention measure. 

Definitions 

The CMA requested clarification of the definitions for: 

process vents, research and development facilities, transfer 

rack, pressure vessels (units used to define pressure), batch 

operation, and halogenated vent stream. Attachment 6 contains 

the mark-ups discussed to clarify the text. 

Transfer 

The CMA had questions on whether the Department of 

Transportation (DOT) test procedures for chemical transporters 

were equivalent, or could be made equivalent, to the Method 27 

test procedures. Also under the DOT rules, the vehicle owner has 

the responsibility to maintain the vapor tightness documentation. 

Since the majority of vehicles are not owned by the SOCMI 

facilities, the draft HON rule provisions would require the SOCMI 

source to also maintain the documentation, thus creating 

additional unnecessary paperwork and making them liable for 

another party. The ESD staff reported that they were looking at 

the DOT test now, but have not completed the evaluation. It was 

also agreed that ESD staff would look at the paperwork burden 

aspects of these requirements. 

Questions were also raised about differences between 

language in Benzene Transfer (40 CFR 61, Subpart BB) provisions 

and the draft HON rule. Paragraphs of particular concern were 

§63.126 (e)(1) and §63.130 (e) of the draft HON rule. The CMA 

expressed the opinion that the pressures specified are only 

applicable to gasoline and are inappropriate for loading of 

chemicals. The ESD staff said that the language would be 
P.7 

reviewed to ensure the provisions are consistent with chemical 

loadings. 

Storage 

Topics discussed regarding the draft storage provisions 

were: (1) omission of provisions for cases where an internal 

floating roof (IFR) is already in service (§63.120 (a)(1)) and 

(2) safety concerns for tank seal inspections. The ESD staff 

agreed that the draft rule should have included provisions to 

address cases where an IFR was already in service. From the 

discussion of the safety issue, it was determined that CMA was 

referring to situations where the tank is structurally unsound, 

i.e., would not hold the weight of a person. The CMA agreed to 

investigate if there are alternative methods for tank seal 

inspections. The ESD staff agreed to consider adding provisions 

for unsafe-to-inspect tanks to the draft rule. These provisions 

were envisioned as being similar to the equipment leak delay-ofrepair provisions and would require replacement of the faulty 

equipment or removal of the hazardous air pollutant from the 

storage vessel within a specified time period. 
P.8 

Attachment 1 

Agenda for HON/CMA Meeting 

04/14/92 

Implementation Plan 8:30 - 9:30 

Recordkeeping & Reporting 9:30 - 11:00 

Vents 11:00 - 12:00 

Lunch 12:00 - 1:00 

Emissions Averaging 1:00-2:00 

Definitions 2:00 - 3:00 

Transfer Operations 3:00 - 3:45 

Storage Vessels 3:45 - 4:30 

Location: Durham OMNI, Suite 106 
• 

-

Attachment 2 

HON IMPLEMENTATION PROGRAM 

Each Owner or operator of 

a source subject to this 

Subpart shall develop an 

implementation program. 

vMtn-esjMC hft i 

PERMIT REGULATIONS (05/10/91) 

§70.3(a) 

Sources subject to 

permitting ... Any source, 

including an area source, 

subject to a standard or 

regulation promulgated 

under section 112 of the 

Act. 

§70.5(a) 

Any person who owns or 

operates a part 70 source 

required to have a permit 

under this part shall submit 

a timely and complete 

permit application. 

TITLE V OF CAA 

§502(a) 

After the effective date of 

any permit program 

approved or promulgated 

under the title, it shall be 

unlawful for any person to 

violate any requirement of 

a permit issued under this 

title, or to operate... a 

major source, any other 

source (including an area 

source) subject to standards 

or regulations under 

sections 111 or 112 ... 

except in compliance with a 

permit issued by a 

permitting authority under 

this title ... The 

Administrator may, in the 

Administrator's discretion 

... promulgate regulations 

to exempt one or more 

source categories (in whole 

or in part) from the 

requirements of this 

subsection... 
HON IMPLEMENTATION PROGRAM PERMIT REGULATIONS (05/10/91) TITLE V OF CAA 

The owner or operator 

shall submit a statement in 

writing notifying the 

Administrator of the 

control measures that will 

be applied to implement 

this standard. 

§70.5(b)(7) 

A compliance plan for 

sources that are not in 

compliance with all 

applicable requirements. 

With respect to the 

requirements for which the 

source is not in compliance, 

such a compliance plan 

shall include the following: 

(i) a description of how 

those requirements under 

the Act will be achieved (ii) 

a description of the 

compliance status of the 

source with respect to such 

requirements (iii) a 

schedule of compliance that 

includes a schedule of 

measures including an 

enforceable sequence of 

actions with milestones, 

leading to compliance with 

all such requirements of the 

Act. 

§503(b) 

The regulations required by 

§502(b) shall include a 

requirement that the 

applicant submit with the 

permit application a 

compliance plan describing 

how the source will comply 

with all applicable 

requirements under the 

Act. The compliance plan 

shall include a schedule of 

compliance, and a schedule 

under which the permittee 

will submit progress reports 

to the permitting authority 

no less frequently than 

every 6 months. 

The implementation 

program shall be 

§70.7(h)(5)(i) 

All permit issuance 

1502(b)(6) 

Adequate, streamlined, and 

VMM2-CS.DO C 

TJ 

. O 
HON IMPLEMENTATION PROGRAM 

incorporated in the 

operating permit for the 

source and shall undergo 

the review and approval 

procedures necessary to 

obtain a permit, prior to 

the compliance dates 

specified in §63.100(0 of 

Subpart F of this part. 

VMM2-OS.DOC F*>3 

PERMIT REGULATIONS (05/10/91) 

proceedings, including 

renewals modifications, and 

reopenings, shall provide 

an opportunity for public 

participation on the draft 

proposed permit. 

§70.6(b) 

All applicable requirements 

under the Act in a part 70 

permit are enforceable by 

the United States and 

citizens under the Act. 

TITLE V OF CAA 

reasonable procedures for 

expeditiously determining 

when applications are 

complete, for processing 

such applications, for 

public notice, including 

offering an opportunity for 

public comment and a 

hearing, and for 

expeditious review of 

permit actions, including 

applications, renewals, or 

revisions... 
HON IMPLEMENTATION PROGRAM PERMIT REGULATIONS (05/10/91) TITLE V OF CAA 

In the case of an existing 

source, the written 

statement describing the 

planned implementation 

program shall be submitted 

within 120 days after the 

effective date. The owner 

or operator shall have 

implemented the program 

by no later than 3 years 

after the effective date. 

§70.5(a) 

For a source applying for 

part 70 permit for the first 

time a timely application is 

one that is submitted 12 

months after the source 

becomes subject to the 

permit program or such 

earlier date as the 

permitting authority may 

establish. 

§70.5(b)(4) 

Citation and description of 

applicable State and 

Federal air pollution 

control requirements, 

including requirements that 

will become effective during 

the term of a permit, if 

such requirement has been 

promulgated at the time of 

permit application. 

§503(c) 

Any person required to 

have a permit shall, not 

later than 12 months after 

the date on which the 

source becomes subject to a 

permit program approved 

or promulgated under this 

title, or such earlier date as 

the permitting authority 

may establish, submit to 

the permitting authority a 

compliance plan and an 

application for a permit 

signed by a responsible 

official, who shall certify 

the accuracy of the 

information submitted. 

VMMMMXK 
HON IMPLEMENTATION PROGRAM PERMIT REGULATIONS (05/10/91) TITLE V OF CAA 

In the case of a new source 

which did not have a 

startup date preceding the 

effective date, the written 

statement shall be 

submitted with the 

application for approval of 

construction or 

reconstruction as described 

in §63.5 of subpart A, and 

the program shall be 

implemented at startup. 

§70.7(g) 

Reopenings shall be 

performed for the following 

reasons: (i) Additional 

requirements under the Act 

become applicable to a 

major part 70 source and 

for which 3 or more years 

remain on the original term 

of the permit. Such 

revisions shall be made not 

later than 18 months after 

the promulgation of 

relevant standards or 

regulations. 

(iv) The EPA determines 

that the permit must be 

revised to assure 

compliance with the 

applicable requirements of 

the Act. 

§502(b)(9) 

A requirement that the 

permitting authority, in the 

case of permits with a term 

of 3 or more years for 

major sources, shall require 

revisions to the permit to 

incorporate applicable 

standards and regulations 

promulgated under this Act 

after the issuance of such 

permit. Such revisions 

shall occur as expeditiously 

as practicable and 

consistent with the 

procedures established 

under paragraph (6) but 

not later than 18 months 

after the promulgation of 

such standards and 

regulations. No such 

revision shall be required if 

the effective date of the 

standards or regulations is 

a date after expiration of 

VMMMSMC ItftS 
HON IMPLEMENTATION PROGRAM PERMIT REGULATIONS (05/10/91) TITLE V OF CAA 

the permit term. 

The written statement shall 

contain the following 

information: 

The identification of each 

§70.5(b) Standard 

application form and 

required information. The 

forms and attachments 

chosen shall include as a 

minimum, the key elements 

§503(c) 

Any person required to 

have a permit shall, not 

later than 12 months after 

the date on which the 

source becomes subject to a 

permit program approved 

or promulgated under this 

title, or such earlier date as 

the permitting authority 

may establish, submit to 

the permitting authority a 

compliance plan and an 

application for a permit 

signed by a responsible 

official who shall certify the 

accuracy of the information 

submitted. 

VMMJ48.DOC 
HON IMPLEMENTATION PROGRAM PERMIT REGULATIONS (05/10/91) 

specified below: 

TITLE V OF CAA 

emission point subject to 

this Subpart and its 

location. §70.5(b)(3)(i) 

All emissions of regulated 

pollutants and all emissions 

of pollutants subject to 

regulation for which the 

source is major. 

§70.5(b)(4)(i) 

Citation and description of 

applicable State and 

Federal air pollution 

control requirements 

including requirements that 

will become effective during 

the term of a permit if such 

requirement has been 

promulgated at the time of 

permit application. 

§70.5(b)(3)(ii) 

Identification and 

description of all emissions 

points in sufficient detail to 

establish the basis for fees 

and applicability of 

requirements of the Act. 

VMM_eJJ}0_ 
HON IMPLEMENTATION PROGRAM PERMIT REGULATIONS (05/10/91) TITLE V OF CAA 

Whether the point is a 

Group 1 or Group 2 

emission point, as specified 

in §63.111 of this Subpart. 

The owner or operator 

shall include, as part of the 

written statement for the 

implementation program 

required in paragraph (a), 

a list designating each 

emission point complying 

with §§63.113 to 63.147, 

and the control technology 

applied. 

§70.5(3) The standard 

application form and 

required information will 

include: 

(v) Identification and 

description of air pollution 

control equipment. 

§70.5(4) 

(i) Citation and description 

of applicable State and 

Federal air pollution 

control requirements. 

After the date compliance is 

required, periodic reports 

of compliance and excess 

emission reports shall be 

submitted as specified in 

§§63.113 through 63.147, 

as applicable. 

§70.6(c) 

All part 70 permits shall 

contain the following 

elements with respect to 

compliance: (1) 

Requirements for 

monitoring and analysis of 

pollutants regulated under 

the Act, including any 

§504(a) 

Each permit issued under 

the title shall Include 

enforceable emission 

limitations and standards, a 

schedule of compliance, a 

requirement that the 

permittee submit to the 

permitting authority no less 

VMMX4BJMC r_tt 
HON IMPLEMENTATION PROGRAM PERMIT REGULATIONS (05/10/91) TITLE V OF CAA 

prescribed by rule by the 

Administrator, sufficient to 

determine if each emission 

unit of the source complies 

with any applicable 

emission limits, standards 

or requirements... (2) 

Compliance certification, 

reporting and 

recordkeeping requirements 

sufficient to assure 

compliance with the terms 

and conditions of the 

permit. Any document 

(including reports) required 

by a part 70 permit shall 

contain a certification by a 

responsible official ... 

often than every 6 months, 

the results of any required 

monitoring, and such other 

conditions as are necessary 

to assure compliance with 

applicable requirements of 

the Act, including the 

requirements of the 

applicable implementation 

plan. 

70.6(a)(3)(iv)(B) 

Require prompt reporting 

of deviations from permit 

requirements including 

those attributable to upset 

conditions as defined in the 

permit, the cause of such 

deviations and any 

corrective action or 

preventative measures 

VMMX2SX>OC 

Tl 
HON IMPLEMENTATION PROGRAM 

The owner or operator 

shall prepare 

implementation programs 

for each alternative control 

or operating scenario 

included in the operating 

permit for the source. The 

implementation programs 

for the alternative control 

VMIOCSHOC ISf. I* 

PERMIT REGULATIONS (05/10/91) 

taken. 

§70.6(a)(6)(v) 

The permittee shall furnish 

to the permitting authority, 

within a reasonable time 

any information that the 

permitting authority may 

request in writing to 

determine whether cause 

exists for modifying, 

revoking and reissuing or 

terminating the permit or 

to determine compliance 

with the permit. 

§70.5(b) Standard 

application form and 

required information. 

§70.5(b)(6) 

Additional information as 

necessary to define 

reasonably anticipated 

alternative operating 

TITLE V OF CAA 
HON IMPLEMENTATION PROGRAM PERMIT REGULATIONS (05/10/91) TITLE V OF CAA 

or operating scenarios shall 

be included in the written 

statement required in 

Paragraph (a) of this 

section. 

scenarios which must be 

included in the part 70 

permit. 

Whenever a new emission 

point is added to a source, 

a written addendum to the 

implementation program 

containing information on 

the new emission point shall 

be submitted. 

§70.6(d)(l) 

The permitting authority 

shall issue permits that 

allow changes to a Part 70 

source without requiring a 

permit revision before the 

source makes such changes, 

if those changes are not 

modifications under any 

provision of Title I of the 

Act and do not exceed the 

emissions allowable under 

the permit, whether 

expressed thereon as a rate 

of emissions or in terms of 

total emissions for any 

timeframe addressed in the 

permit. 

§502(b)(10) 

Provisions to allow changes 

within a permitted facility 

(or one operating pursuant 

to section 503(d) without 

requiring a permit revision, 

if the changes are not 

modifications under any 

provision of Title I and the 

changes do not exceed the 

emissions allowable under 

the permit (whether 

expressed therein as a rate 

of emissions or in terms of 

total emissions: Provided, 

that the facility provides 

the Administrator and the 

permitting authority with 

written notification in 

VMHMHMC 
HON IMPLEMENTATION PROGRAM PERMIT REGULATIONS (05/10/91) TITLE V OF CAA 

§70.6(d)(2) 

If a part 70 source wishes 

to make a change that 

would increase any 

emission above a level 

allowed in the permit, and 

such change is not a 

modification under any 

provision of Title I of the 

Act and would not be 

prohibited by any 

applicable requirement 

under the Act, then the 

source shall be required to 

revise its permit pursuant 

to procedures established 

by the State. Such 

procedures may provide for 

maximum flexibility, 

provided they meet the 

requirements set forth 

under §70.(7)(f). 

changes which shall be a 

minimum of 7 days, unless 

the permitting authority 

provides in its regulations a 

different timeframe for 

emergencies. 

§70.6(3) 

...Any changes, including 

emissions increases, which 

are included in such 

reasonably anticipated 

scenarios, shall be allowed 

VMMVCS-DOC 

o 
HON IMPLEMENTATION PROGRAM PERMIT REGULATIONS (05/10/91) TITLE V OF CAA 

without requiring a permit 

revision. 

(ii) For pollutants regulated 

at the source allowing 

changes in the operation of 

a facility which are not 

included in the permit as a 

reasonably anticipated 

operating scenario that 

would not increase either 

the rate of emissions or 

total emissions beyond what 

is allowed under any 

timeframe addressed by the 

permit. For any such 

change, the source shall 

provide the permitting 

authority and EPA with 7 

calendar days advance 

written notification. Such 

notification shall describe 

the proposed changes, 

including changes in 

emissions, and any 

requirements that would be 

applicable as a result of the 

changes. 

VMMMOIJWC 

Tl 

ho 
HON IMPLEMENTATION PROGRAM PERMIT REGULATIONS (05/10/91) TITLE V OF CAA 

§70.7(g)(l) 

Each issued permit shall 

include provisions 

addressing the conditions 

for revision prior to the 

expiration of the permit... 

Reopenings shall be 

performed for the following 

reasons: ...(iv) EPA 

determines that the permit 

must be revised to assure 

compliance with the 

applicable requirements of 

the Act. 

§70.7(g)(5) 

The permitting authority 

shall reopen a part 70 

permit pursuant to §70.7(g) 

whenever the permitting 

authority or the 

administrator determines 

that any permit revision 

accomplished pursuant to 

§70.7(0 does not assure 

compliance with all 

applicable requirements of 

the Act or did not qualify 

for processing under 

VMMMS.DOC 
P.23 

APR-13-1992 15:24 FROM CHEM. MANUFACTURERS ASSN. TO 919195414028 P.05 

Implementation Plans 

EPA has proposed that each source subject to the standard submit 

an "implementation plan" to the permitting authority within 120 days of 

promulgation. The plan is supposed to identify, in great detail, each 

emission point subject to the rule and how the source will get that 

point into compliance. 

The operating permit application vill address every item 

proposed for inclusion in the implementation plan - identification of 

emission points, compliance methods, recordkeeping, reporting, and 

monitoring requirements. 

Recognizing that this information will be complex and difficult to 

assemble, the statute allows a source 12 months after promulgation of a 

HACT standard to complete a permit application. While even that may be 

short in some cases, it is certainly more realistic than 120 days. 

It is important to note that even if the permit program is not 

operational by the HON compliance date, each source subject: to the rule 

will still have a legal obligation to be in compliance. That Includes 

regular submission of all the reports detailed in the HON. EPA has 

the authority to enforce the HON directly against any source subject to 

the rule, permit or no permit. (See General Provisions ati 

163.5(b)(5)) 

Sources subject to any MACT standard have two statutory 

requirements - to be ln compliance by the compliance deadline and to 

obtain an operating permit. Since there is no statutory basis for an 

implementation plan, and preparing one in 120 days would overwhelm both 

sources and the personnel reviewing the plans, it seems much more 

reasonable to focus attention on putting together a complete, detailed 

permit application. 
P.24 

APR-13-1.992 15:25 FROM CHEM. MANUFACTURERS ASSN. TO 919195414028 P.06 

NOTIFICATION REQUIREMENTS 

§63.151 Initial Notification 

(a) Each owner or operator of a source subject to Subpart 

G that has an initial startup prior to the proposal date shall 

notify the Administrator in writing that the source is subject 

to the Subpart. The notification shall be submitted within 90 

i 

days after the. effective date of Subpart G and shall include 

the following information: 

(1) The name and address of the owner/operator; 

(2) The address (physical location) of the affected 

source; 

(3) An identification of the standards included in 

Subparts G that are the basis of the notification; and 

(4) A brief description of the nature, size, and 

i 

operation of the source. I 
Attachment 3 

REPORTING AND RECORDKEEPING SUMMARY 

EMISSION POINT: PROCESS VENT 

Records 

or 

Reports 

Report 

Report 

Record 

Report 

Record 

Report 

Record 

Requirement 

Category : 

Initial 

Report 

Initial 

Report 

Initial 

Record 

Initial 

Report 

Unspecified 

Unspecified 

Performance 

Test 

; Emission 

joints 

Affected 

N&E, Group 1 

N&E, Group 1 

N&E, Group 1 

N&E, Group 1 

N&E, Group 1 

N&E, Group 1 

N&E, Group 1 

Regulation 

Reference 

63.117(a) 

63.117(a) 

63.117(c) 

63.117(c) 

63.117(d) 

63.117(d) 

63.117(b) 

Control 

Technique 

Any control 

device 

Any control 

device 

Any combustion 

device 

Any combustion 

device 

Alternative 

compliance 

method 

Alternative 

compliance 

method 

Any control 

device 

Incinerators, 

scrubbers, and 

boiler/process 

heater <44 MW 

and vent 

stream is not 

the primary 

fuel 

Requirement Summary 

Report selected compliance 

method 

Report change in selected 

compliance method 

Conduct performance test 

Schematic diagram of vent, 

collection system, fuel system, 

combustion device, and bypass 

system 

Submit schematic diagram from 

63.117(c) 

Administrator will specify 

recordkeeping requirements 

Administrator will specify 

reporting requirements 

Operating parameters from 

Table 3 averaged over test and 

Percent reduction or outlet 

concentration 

Timeframe 

Due with 

implementation 

plan 

Due 90 days 

before change 

Due within 

180 days of 

completion of 

change 

Maintain for 

life of the 

equipment 

Due with 

implement at ion 

plan 

Unknown 

Unknown 

Maintain for 

5 years 

rrsunm.Dv 
REPORTING AND RECORDKEEPING SUMMARY 

EMISSION POINT: PROCESS VENT (CONTINUED) 

Records 

Reportsi 

Report 

Record 

Report 

Record 

Report 

Report 

Requirement 

-Category 

Performance 

Test 

TRE 

Calculation 

TRE 

Calculation 

TRE 

Calculation 

TRE 

Calculation 

TRE 

Calculation 

Emission 

Points 

Affected 

N&E, Group 1 

N&E, Group 2 

N&E, Group 2 

N&E, Group 2 

N&E, Group 2 

N&E, Group 2 

with TRE 

>8.0 

Regulation 

Reference 

63.117(b) 

63.117(b)(iv) 

63.117(b)(iv) 

63.117(b)(iv) 

63.117(b)(iv) 

63.117(b)(v) 

Control 

Technique 

Any boiler/ 

process heater 

Flare 

Any control 

device 

Any product 

recovery 

device 

Any product 

recovery 

device 

None 

None 

None 

— \ 

Description of where vent strean 

is introduced \ 

Flare design and periods of \ 

visible emissions \ 

Submit all data from 63.117(b) \ 

for initial test and any 

subsequent tests (subsequent 

test required for combustion 

device efficiency or outlet 

concentration) 

Operating parameters from 

Table 4 averaged over test 

Report monitored operating 

parameter test data from 

63.117(b)(iv), Table 4 for 

initial and any subsequent TRE 

calculations 

TRE calculation data 

TRE calculation data for initial 

and any subsequent TRE 

calculations 

Initial TRE calculation data 

Timeframe 

Initial report 

^due within 

30 days of test 

(63.7); 

subsequent 

report timeframe 

unknown 

Maintain for 

5 years 

Initial report 

due within 

30 days of TRE 

calculation; 

subsequent 

report timeframe 

unknown 

Maintain for 

5 years 

Initial report 

due within 

30 days of TRE 

calculation; 

subsequer.L 

report unk:--. -a • 

Due within 

30 days of TRE 

calculation 

rrsumn.pv 

ho 

0) 
REPORTING AND RECORDKEEPING SUMMARY 

EMISSION POINT: PROCESS VENT (CONTINUED) 

Records 

or 

Reports 

Record 

Report 

Record 

Report 

Requi rement 

Category 

Monitoring 

and 

Exceedances 

Exceedances 

Monitoring 

and 

Exceedances 

Exceedances 

Emission 

Points 

Affected 

N&E, Group 1 

N&E, Group 1 

N&E, Group 2 

with TRE 

<8.0 

N&E, Group 2 

with TRE 

<8.0 

Regulation 

Reference 

63.118(a) 

63.118(d) 

63.118(b) and 

63.113(e) 

for TRE 

exclusion 

63.118(d) and 

63.113(e) 

for TRE 

exclusion 

Control 

Technique 

Any combustion 

device 

Any combustion 

device 

Any recovery 

device 

Any recovery 

device 

Requirement Summary 

Operating parameters from 

Table 3, 63.117 

Periods when parameters 

exceeded 

Continuous flow and 

periods when flow 

diverted; if seal used, 

monthly inspection records 

Exceedances of operating 

parameters 

Periods when vent stream 

diverted 

Periods when flare pilot 

flame is out 

Operating parameters from 

Table 4, 63.117 

- Periods when parameters 

exceeded 

Exceedances of operating 

parameters 

Timeframe' 

Up-to-date and 

for the past 

5 years 

Due each 

quarter; initial 

report due 

within 6 months 

Up-to-date and 

for the past 

5 years 

Due each 

quarter; initial 

report due 

within 6 months 

rtsunm.DV 
REPORTING AND RECORDKEEPING SUMMARY 

EMISSION POINT: PROCESS VENT (CONTINUED) 

Records 

or 

Reports 

Record 

Report 

Requirement 

Category 

TRE 

Calculation 

TRE 

Calculation 

Emission 

Points 

Affected 

N&E, Group 2 

N&E, Group 2 

Regulation 

Reference 

63.118(c) 

63.118(d)(5) 

Control 

Technique 

None 

None 

Requirement Summary 

For a process unit change 

(capacity, feedstock, catalyst, 

recovery equipment) 

Description of change 

TRE calculation data per 

63.115(c) 

For TRE <8.0, recovery 

device performance test 

data from TRE calculation 

Description of process 

unit change 

TRE calculation data 

Timeframe 

Up-to-date and 

for the past 

5 years 

Due each 

quarter; initial 

report due 

within 6 months 

rrsumm.pv 
REPORTING AND RECORDKEEPING SUMMARY 

EMISSION POINT: STORAGE VESSEL 

Records 

or 

Reports 

Record 

Record 

Report 

Record 

Record 

Requirement 

Category 

Initial 

Record 

Initial 

Record 

Initial 

Report 

Monitoring 

Inspections 

Emission 

Points 

Affected 

N&E, Group 1 

and 2 

N&E, Group 1 

N&E, Group 1 

N&E, Group 1 

N&E, Group 1 

Regulation 

Reference 

63.124(a) 

63.124(e)(1) 

63.122(a)-(d) 

63.124(e)(2) 

63.124(b)-(d) 

Control 

Technique 

None 

Closed Vent 

Systems with 

Control 

Device 

Tank 

Modifications 

or Closed 

Vent System 

with Control 

Device 

Closed Vent 

Systems with 

Control 

Device 

Internal 

Floating Roof 

with Fixed 

Roof or When 

Converting 

External 

Floating to 

Internal 

Floating Roof 

Requirement Summary 

Record dimensions and capacity 

of vessel 

Keep detailed operating and 

maintenance plans required in 

63.120(d)(2) & (3) 

Describe controls applied to 

attain compliance (different 

formats specified for closed 

vent systems depending upon 

control device used) 

Record operating parameters 

selected and described in the 

operating plan required by 

63.120(d)(2) 

Record inspections specified in 

63.120(a), includes inspections 

prior to filling and annual 

visual inspections; for external 

floating roof: seal gap 

measurements data as specified 

in 63.120(b) 

Timeframe 

_ 

Life of equipment 

Life of equipment 

Existing: for 

flare, due within 

3 years of 

effective date; 

for device other 

than flare, due 

with 

implementation 

plan 

New: depends on 

control device 

and start-up date 

As required; 

depends on plan 

Variable; at 

least annually 

! 

rcsucm.st 
REPORTING AND RECORDKEEPING SUMMARY 

EMISSION POINT: STORAGE VESSEL (CONTINUED) 

Records 

or 

Reports 

Record 

Record 

Report 

Report 

Requirement 

Category 

Inspections 

Exceedances 

Exceedances 

Exceedances 

Emission 

Points 

Affected 

N&E, Group 1 

N&E, Group 1 

N&E, Group 1 

N&E, Group 1 

Regulation 

Reference 

63.124(e)(4) 

and (5) 

63.124(e)(3) 

63.123(a)-(c) 

63.123(d) 

Control 

Technique 

Closed Vent 

System with 

Control 

Device 

Closed Vent 

System with 

Control 

Device 

Internal 

Floating 

Roof, 

External 

Floating 

Roof, or 

Conversion of 

External to 

Internal 

Closed Vent 

System with 

Control 

Device 

Requirement Summary 

Identify, explain why, and 

provide plan for inspection of 

parts of control equipment that 

are unsafe or difficult to 

inspect 

Record maintenance activities to 

include all periods when control 

equipment is out of 

specification with 63.119(e) 

Describe inspections where 

failures found; detail provided 

defining a failure and required 

information about failure and 

subsequent repair for each type 

of inspection 

Report occurrences of excess 

emissions as evidenced by: 

1) monitored parameters 

2) measurements made for flames, 

or 3) control system malfunction 

(required contents of report 

described) 

Timeframe 

Unspecified; can 

assume for life 

of equipment 

As required by 

maintenance 

activities 

Due within 

60 days of 

inspections; 

within 15 days of 

repair if 

extension granted 

Quarterly; no 

report due if no 

excess emissions 

[63.123(d)(4)] 

i 

rrsumm.st 
REPORTING AND RECORDKEEPING SUMMARY 

EMISSION POINT: TRANSFER 

Records 

or 

Reports 

Record 

Record 

Record 

Requirement 

Category 

Initial 

Record 

Initial 

Record 

Initial 

Record 

Emission 

Points 

Affected 

N&E, Group 1 

and 2 

N&E, Group 1 

N&E, Group 1 

Regulation 

Reference 

63.129 (c) 

63.129 (d) 

63.130 (e)(f) 

Control 

Technique 

None 

Any control 

device 

None 

Requirement Summary 

Design of loading rack and 

analysis showing throughput, 

weight percent organic HAP, and 

average vapor pressure. 

Describe vent system used to 

vent to control device. 

Vapor tightness documentation 

[63.126 (e)] for vehicles. 

Timeframe 

Up-to-date and 

for the past 

5 years 

Up-to-date and 

for the past 

5 years 

On file at 

loading rack in 

permanent form 

available for 

inspection; 

update annually. 

rrsusxn.tr 

CO 
REPORTING AND RECORDKEEPING SUMMARY 

EMISSION POINT: TRANSFER (CONTINUED) 

Records 

or 

Reports 

Record 

Requirement 

Category 

Performance 

Test 

Emission 

Points 

Affected 

N&E, Group 1 

Regulation 

Reference 

63.129 (a) 

Control 

Technique 

Incinerator 

Flare 

Boiler or 

Process Heater 

Absorber 

Requirement Summary 

- average firebox 

temperature 

- percent reduction or 

outlet concentration 

duration of loading cycles 

- all visible emissions, 

heat content 

determinations, etc., made 

during performance test 

continuous pilot flame 

measurements 

duration of all loading 

cycles 

all cycles when pilot 

flame is out 

where vent stream 

introduced 

- average combustion 

temperature for capacity 

<44 MW 

duration of loading cycle 

- exit specific gravity or 

alternative parameters 

- percent reduction or 

outlet concentration 

- duration of loading cycle 

Timeframe 

Up-to-date and 

for the past 

5 years 

-

rrsunm. tr' 
REPORTING AND RECORDKEEPING SUMMARY 

EMISSION POINT: TRANSFER (CONTINUED) 

Records 

or! 

Reports 

Record 

Report 

Requirement 

Category 

Performance 

Test 

Performance 

Test 

Emission 

Points 

Affected 

N&E, Group 1 

N&E, Group 1 

Regulation 

Reference 

63.129 (a)(7) 

63.129 (a) 

Control 

Technique 

Condenser 

Carbon 

Adsorber 

Scrubber 

Any Recovery 

Device 

Incinerator, 

Flare, Boiler, 

Process 

Heater, 

Absorber, 

Condenser, 

Carbon 

Adsorber, 

Scrubber 

Requirement Summary 

average exit temperature 

- percent reduction or 

outlet concentration 

duration of loading cycle 

total steam mass flow, 

temperature of carbon bed 

after regeneration and 

duration of carbon bed 

steaming cycle 

percent reduction or 

outlet concentration 

duration of loading cycle 

- percent reduction or 

outlet concentration 

average pH of scrubber 

effluent 

average L/G 

Allowed concentration level 

monitoring 

Report performance test data as 

specified in 63.129 (a)(l)-(8); 

varies for different control 

devices. 

Timeframe 

Up-to-date and 

for the past 

5 years 

Initial report: 

30 days after 

test 

rrsimm.tr 

co 

co 
REPORTING AND RECORDKEEPING SUMMARY 

EMISSION POINT: TRANSFER (CONTINUED) 

Records 

or 

Reports 

Report 

Record 

Record 

Record 

Report 

Requirement 

Category 

Performance 

Test 

Monitoring 

Monitoring 

Monitoring 

Exceedance 

Emission 

Points 

Affected 

N&E, Group 1 

N&E, Group 1 

N&E, Group 1 

N&E, Group 1 

N&E, Group 1 

Regulation 

Reference 

63.129 (b) 

63.130 (a) 

63.130 (b) 

63.130 (c) 

63.130 (d) 

Control 

Technique 

Boiler or 

Process Heater 

> 44 MW 

Any Control 

Device 

Any Control 

Device 

Flare 

Any Control 

Device 

Requirement Summary 

Report location where vent 

stream introduced 

Equipment operating parameters 

(Table 7) , periods of 

exceedances of parameters, and 

changes in vent stream location 

for boilers 

Continuous flow data or times 

when seal is broken when 

diverting stream from control 

device. (Table 7) 

Data on flare pilot flame or 

absence of flame during loading 

cycle. 

Report data on exceedances of 

monitored parameters, periods 

when vent stream is diverted, 

periods when flare pilot flame 

absent. 

Timeframe 

Initial report: 

30 days after 

test 

Up-to-date and 

for the past 

5 years 

Up-to-date and 

for the past 

5 years 

Up-to-date and 

for the past 

5 years 

Quarterly 

rrsurwn.tr 
REPORTING AND RECORDKEEPING SUMMARY 

EMISSION POINT: WASTEWATER 

Records 

Reports 

Record 

Record 

Record 

Record 

Record 

Record 

Requirement 

Category 

Initial 

Record 

Initial 

Record 

Initial 

Record 

Initial 

Record 

Initial 

Record 

Initial 

Record 

Emission 

Points 

Affected 

N&E, 

Group 1 and 

Group 2 

N, 

Group 1 and 

Group 2 

N&E, 

Group 1 and 

Group 2 

N&E, 

Group 1 and 

Group 2 

N&E, 

Group 1 

N&E, 

Group 1 

Regulation 

Reference 

63.146(b) 

63.146(b)(1) 

63.146(b)(2) 

63.146(b)(3) 

63.146(b)(4) 

63.146(b)(5) 

Control 

Technique 

None 

Options under 

63.138(b) for 

streams 

identified by 

63.132(c) 

Options under 

63.138(c) for 

streams 

identified by 

63.132(d) 

Alternative 

standards in 

63.138(d) for 

streams 

identified by 

63.132(c) or 

(d) 

Treatment 

processes 

Residual 

treatment 

(63.138(f)) 

Requirement Summary 

Flow diagram showing each 

Wastewater stream, point of 

generation, stream 

identification 

Per stream; VOHAP concentration, 

flow rate, controlled (V or N), 

treatment process selected 

(Table 14) 

Per stream; VOHAP concentration, 

flow rate, point of generation 

mass flow rate, Group 1 or 2 

status, identify control method, 

treatment process, revised mass 

flow rate (Table 15) 

Per stream total VOHAP 

concentration, flow rate, 

controlled (Y or N), treatment 

process selected (Table 16) 

Description, identify streams 

treated, identify parameters to 

be monitored 

Per residual; control device 

description and efficiency 

Timeframe 

Life of equipment ' 

Life of equipment 

Life of equipment 

Life of equipment 

Life of equipment 

Life of equipment 

irsumD.ww 
REPORTING AND RECORDKEEPING SUMMARY 

EMISSION POINT: WASTEWATER (CONTINUED) 

Records 

or 

Reports 

Record 

Record 

Record 

Record 

Record 

Requirement 

Category 

Initial 

Record 

Performance 

Test 

Performance 

Test 

Performance 

Test 

Exceedances 

Emission 

Points 

Affected 

N&E, 

Group 1 

N&E, 

Group 1 

N&E, 

Group 1 

N&E, 

Group 1 

N&E, 

Group 1 

Regulation 

Reference 

63.146(c) 

63.146(d) 

63.146(e) 

63.146(f) 

63.146(g) 

Control 

Technique 

Wastewater 

Transfer 

r63.132(e)l 

Cover 

Any control 

device 

Waste 

Management 

Unit 

(63.138) 

Any control 

device 

(63.139) 

Waste 

Management 

Unit (63.138) 

Requirement Summary 

Date, quantity, identification 

of receiver, copy of notice 

Description, materials, 

dimensions, openings, seals 

63.146(f) 

If engineering calcs, complete 

design analysis [63.146(e)(1)] 

If performance test, description 

of equipment, test protocol, 

operating conditions, test 

results 

if control device used, 

63.146(f) 

For engineering calcs, control 

device description, vent stream 

characteristics, and other 

specifics for each device [(A) 

through (G)] 

For performance test, 

documentation that Waste 

Management Unit is at peak mass 

flow rate, control device 

description, sampling and 

monitorinq, test results 

For startup and shutdown, 

periods when equipment not 

operated as desiqned and from 

Table 19 but not text 

problems found in quarterly 

inspections, test results and 

problems from annual equipment 

sniffing 

Timeframe 

Up-to-date and 

for 2 years 

Life of equipment 

Life of equipment 

Life of equipment 

Up-to-date and 

for 2 years 

rrsumm.ww 

co 

CD 
REPORTING AND RECORDKEEPING SUMMARY 

EMISSION POINT: WASTEWATER (CONTINUED) 

Record* 

or 

Reports 

Record 

Record 

Record 

Report 

Report 

Report 

Requirement 

Category 

Monitoring 

and 

Exceedances 

Unspecified 

Monitoring 

and 

Exceedances 

Initial 

Report 

Initial 

Report 

Monitoring 

and 

Exceedances 

Emission 

Points 

Affected 

N&E, 

Group 1 

N&E, 

Group 1 

N&E, 

Group 1 

N&E, 

Group 1 

N&E, 

Group 1 

N&E, 

Group 1 

Regulation 

Reference 

63.146(h) 

63.146(i) 

63.146(j) 

63.147(a) and 

(b) 

63.147(c)(1) 

63.147(c)(2) 

Control 

Technique 

Any control 

device 

Tank controls 

(63.141) 

Oil water 

separator 

(63.142) 

None 

Biological 

treatment 

unit 

Waste 

Management 

Unit 

Waste 

Management 

Unit 

Treatment 

processes 

Requirement Summary 

For startup and shutdown, 

periods when not operated as 

designed, periods, when flare 

pilot flame is out, raw data 

from continuous recording 

devices, records from Table 19 

(different for each control 

device) 

For wastewater tanks using 

40 CFR 60.115, keep required 

records from that rule 

Visual inspections when problems 

found, seal gap measurements 

Process unit flow diagram as 

recorded for 63.146(b); update 

when process unit change occurs 

Describe and justify selection 

of alternative monitoring 

parameters 

Table 19 provides more detail 

Visual leak inspection results 

Results of equipment sniffing 

Monitoring exceedances 

Timeframe' 

Up-to-date and 

for 2 years 

Unknown 

Up-to-date and 

for 2 years 

Existing: due 

within 90 days of 

promulgation 

new: due by 

initial startup 

Due with 

implementat ion 

plan 

Initial and 

quarterly 

Initial and 

annual 

Initial and 

quarterly 

rrsumn.ww 
REPORTING AND RECORDKEEPING SUMMARY 

EMISSION POINT: WASTEWATER (CONTINUED) 

Records 

or 

Reports 

Report 

Report 

Report 

Requirement 

Category 

Initial 

Report 

Unspecified 

Exceedances 

Emission 

Points 

Affected 

N&E, 

Group 1 

N&E, 

Group 1 

N&E, 

Group 1 

Regulation 

Reference 

63.147(d) 

63.147(e) 

63.147(f) 

Control 

Technique 

Any 

combustion 

device 

Any control 

device 

Tank controls 

or oil water 

separators 

(63.141 or 

142) 

Tank controls 

(63.141) 

Oil/water 

separators 

(63.142) 

Requirement Summary 

Diverting vent stream 

Monitoring exceedances 

Notify Administrator of plans 

for complying with alternative 

provisions of 63.141 or 63.142 

For wastewater tanks using 

40 CFR 60.115, submit reports 

required under that rule 

Seal gap measurements 

Timeframe 

Quarterly 

Initial and 

quarterly 

Due with 

implementat ion 

plan 

Unknown 

Initial and 

quarterly 

rcsumn.ww 
APR-13-1992 15:25 FROM CHEM. MANUFACTURERS ASSN. TO 919195414028 P.07 

i" 

Attachment .4 . 

Monitoring, Recordkeeping and Reporting Requirements for Vents 

with TRE Levels Greater than One 

The draft proposal would reguire extensive 

monitoring and recordkeeping for vents with TRE values greater 

than one and less than eight. This is an unwarranted drain on 

operators' compliance resources with no environmental benefit 

in return. 

Only those Group 2 vents which have TRE values 

greater than one because of a recovery device should be 

specifically subject to monitoring and recordkeeping under the 

HON- The HON should not require monitoring for those vents 

which maintain a TRE above one without relying on a recovery 

device. 

A source's operating permit may nonetheless require 

monitoring of vents that do not require controls. The HON 

should allow for the operating permit to specify parameter 

ranges to be maintained as a measure of TRE. 

The suggested revision would replace §63.114(b) and 

add a new §63.114(c). The remainder of the section Would be 

renumbered accordingly. §63.114(b) places monitoring 

requirements on vents which rely on a recovery device to 

maintain a TRE value greater than one. The concept found in 

new §63.114(c) is that vents with a TRE inherently above one 

are subject to minimal requirements. Other language changes 

are required in sections 113 through 118 to make this concept 

consistent throughout the vents provisions. 
— — . . P.40 

APR-13-1992 15:25 FROM CHEM. MANUFACTURERS ASSN. TO 919195414028 P.08 

MONITORING, RECORDKEEPING AND REPORTING REQUIREMENTS FOR 

VENTS WITH TRE VALUES GREATER THAN ONE 

§63.114(b) - Each owner or operator of a process vent that 

complies with §63.113 by maintaining the TRE 

index value greater than 1.0 through the use 

of a final recovery device shall either 

monitor the vent emissions with an organic 

monitoring device with a continuous recorder 

or shall monitor the operation of the recovery 

device as specified in paragraphs (b)(1), (2), 

or (3) of this section or shall monitor as 

otherwise provided in the Title V operating 

permit for such vent. All monitoring 

equipment shall be installed, calibrated, and 

maintained according to the manufacturers 

specifications. 

(1) Where an absorber is the final; recovery 

device in the recovery system,j monitor 

and record the scrubbing liquid 

temperature and specific gravity. 

I • 

(2) Where a condenser is the final1 recovery 

device in the recovery system, monitor 

and record the condenser exit (product 

side) temperature. 

(3) Where a carbon adsorber is the final 

recovery device in the recovery system, 

monitor and record the stream flow and 

carbon bed temperature. 

§63.114(c) - Each owner or operator of a process vent that 

complies with §63.113 without relying on a 

recovery device such as an absorber, condenser 

or carbon adsorber to maintain the TRE greater 

than 1.0 shall notify the Administrator within 

15 days if a change causes the TRE to become 

less than or equal to 1.0 and shall comply 

with §63.113. The Title V operating permit 

may specify an operating parameter range to be 

maintained as an indicator of TRE. 

Change §63.114(c) to be new 63.114(d) 

Change §63.114(d) to be new 63.114(e) 
P.41 

•> ••• DAPR-13-199 C 2 15=26 FROM CHEM. MANUFACTURERS ASSN. TO 919195414028 P. 09 

Bypass, Low Leg Drains, and High Point Bleeds 

CMA recommends that paragraph 63.114(d) be written as follows 

(underlined sections have been changed): 

§63.114 Process vent provisions - monitoring requirements 

(d) The owner or operator of a process vent using a vent 

system that contains bypass lines that could divert vent stream 

flow away from the combustion device used to comply with 

Section 113(a)(1); or (2) must comply with Section 114(d)(1) or 

(2). Equipment such aa low leg drains, high point bleeds, 

analyzer vents and other equipment subject to Section 63.167 

are not subject to Section 63.114(d)(1) and (2). 
P.42 

Attachment 5 

ACTUAL vs. ALLOWABLE 

Issue: Should actual or allowable emissions 

estimates be used for averaging? 

Emissions Point 1 Point 2 Point 3 Total 

Scenario 1 

Uncontrolled 100 50 50 200 

Controlled w/o EA 2 50 50 102 

Controlled w/EA 100 1 1 102 

Debits = 98 Credits = 49 + 49 = 98 

Scenario 2 

Uncontrolled 100 50 25 175 

Controlled w/o EA 2 50 25 77 

Problem: Anticipate Scenario 1, Experience 2 

EA w/Allowables 100 1 0.5 101.5 

Debits = 98 Credits = 49 + 49 = 98 

EAw/Actuals 100(75) 1 0.5 101.5 

Debits = 98 Credits = 49 + 24.5 = 73.5 

w/Allowables, no penalties for the 24.5 extra tons 
Attachment 6 

the purpose of producing transportation fuels (such as 

gasoline and diesel fuels), heating oils (such as distillate 

and residual fuel oils), or lubricants; separates petroleum; 

or separates, cracks, or reforms unfinished derivatives. 

Examples of such units include, but are not limited to, 

alkylation units, catalytic hydrotreating, catalytic 

hydrorefining, catalytic hydrocracking, catalytic reforming, 

catalytic cracking, crude distillation, and thermal 

processes. «_*— 

Plant site means all contiguous or adjoining property 

that is under common ownership or control, including 

properties that are separated only by a road or other public 

right-of-way. Common ownership or control includes 

properties that are owned, leased,or operated by the same 

entity, parent entity, subsidiary, or any combination 

thereof. , / 

Process vent means Aay gas stream that is/\discharged 

$\j{-.r\c~\ i^< —t>from an air oxidation process unit, reactor process unit, or 

• T T , 4 distillation operation within a chemical manufacturing 

•VW 0r\O\ 

process that meets all applicability criteria in §63.100 of 

this Subpart and 563.110 of Subpart G. Process vents 

include gas streams that are discharged directly to the d^L-Vatmosphere and gas streams discharged (indir eet ly) to the S4XL-b" 

•atmosphere after diversion through a product recovery 

0/1 

device. Process vents exclude relief valve discharges and 

308 
P.44 

leaJcs from equipment regulated under Subpart H of this Part, 

but include vents from product accumulator vessels. 

Product means any compound or chemical listed in 

$63,105 of this Subpart, which is manufactured as a final 

product as that chemical, or for use in the production of 

other chemicals or compounds. Co-products, by-products, and 

isolated intermediates that are separated and subsequently 

used in other processes are considered to be products. 

Reaction intermediates that are never isolated are not 

considered products. 

Recovery device means an individual unit of equipment 

capable of and used for the purpose of recovering chemicals 

for use, reuse, or sale. Recovery devices include, but are 

not limited to, absorbers, carbon adsorbers, and condensers. 

Research and development facility means laboratory and 

pilot plant operations whose primary purpose is to conduct 

research and development into new processes and products, 

where the operations are under the close supervision of 

technically trained "personnel, and is not engaged in the 

manufacture of products for commercial sale, except in a 

de minimis manner. Re_aagate—iM_-4evoi_cpaew* fae___l?_nf 

m t _ws_uds market dsvsispmenfc facilities. 

storage vessel means a tank or other vessel within a 

&OuO chemical manufacturing process that is used to store one or 

more organic HAP's and meets all applicability criteria in 

309 
P.45 

S63.100 of this Subpart and S63.110 of Subpart C. The 

storage vessel does not include: 

(1) Vessels permanently attached to motor vehicles 

" such as trucks, railcars, barges, or ships; 

(2) Pressure vessels designed to operate in excess of 

.9 kilopascals*and without emissions to the atmosphere; 

(3) Vessels with capacities smaller than 

10,000 gallons. 

Transfer operation means the loading of one or more 

liquid organic HAP's with a vapor pressure less than or 

equal to 2^04.9 Jcilopascals from a transfer rack within a 

chemical manufacturing process to which this Subpart applies 

into a tank truck or railcar. 

Transfer rack, means the loading arms, pumps, meters, 

shutoff valves, relief valves, and other piping and valves 

necessary to fill tank trucks or railcars. Transfer racks 

percdftOAS OoMc^ include racks transferring organic HAP's with vapor 

YMJZ rjo.r^'GoS€£ " pressures less than or equal to 204.9 kilopascals and do not 

or (2), fraAS^i 

fojn^^^P ^IncludeAtransfer of HAP's with vapor pressures greater than 

" K 

204.9 kilopascals> v 

Volatile hazardous air pollutant or VflAj>, as used in 

this Subpart and Subpart H means a substance listed in 

S63.183 of Subpart H. 

Wastewater means any organic HAP-containing liquid or 

* « . 

material separated from the liquid that results from direct 

-Y ._*: 

-JIG 

NCJLA te 

U o /T vx t -Vu CLIA <^ "vvr"

L

 7 ^ ' \ °^°- 0 

, . .. I • I ,.l . 
Average concentration, as used in the wastewater 

provisions, means the flow-weighted annual average 

concentration, as determined according to the procedures 

specified in §63.144(b). 

Average flow rate, as used in the wastewater 

provisions, means the annual average flow rate, as 

determined according to the procedures specified in 

§63.144(e). 

Batch operation means a noncontinuous operation in 

which a discrete quantity or batch of feed is charged into a 

process unit and distilled or reacted at one time. 

the initial charging of the feed, no additional feed is 

added during the operation. 

Boiler means any enclosed combustion device that 

extracts useful energy in the form of steam and is not an 

incinerator. 

By compound means by individual stream components, not 

carbon equivalents. 

Car-seal means a seal that is placed on a device that 

is used to change the position of a valve (e.g., from opened 

to closed) in such a way that the position of the valve 

cannot be changed without breaking the seal. 

Closed-vent svstem means a system that is not open to 

the atmosphere and is composed of piping, ductwork, 

connections, and, if necessary, flow inducing devices that 

335 
P.47 

l^^ f f\ - H-£-c H-o-f o_^ ^ a^yl c MAP . ^ H-^_ 

Marine vessel means any tank ship or tank barge which 

transports liquid product such as organic HAP. 

Mass flow rate, as used in the wastewater provisions, 

means the mass of a constituent in a wastewater stream, 

determined by multiplying the average concentration of that 

constituent in the wastewater by the annual volume of the 

wastewater stream. 

Maximum true vaoor pressure means the egui">ibriuTM 

Oj^x-2+^fy 

partial pressure exerteaBypthe stored liquid at the 

temperature equal to the highest calendar-month average of 

the liquid storage temperature for liquids stored above or 

below the ambient temperature or at the local maximum 

monthly average temperature as reported by the National 

Weather Service for liquids stored at the ambient 

temperature, as determined: 

(1) In accordance with methods described in American 

Petroleum Institute Bulletin 2517, Evaporation Loss From 

External Floating Roof Tanks; or 

(2) As obtained from standard reference texts; or 

(3) As determined by the American Society for Testing 

and Materials Method D2879-83; or 

(4) Any other method approved by the Administrator. 

Metallic shoe seal or mechanical shoe seal means a 

metal sheet that is held vertically against the wall of the 

storage vessel by springs, weighted levers, or other 

mechanisms and is connected to the floating roof by braces 

342 
V 

g ^ 

N 

'. 

floating roof and is mounted such that there is a vapor 

space between the stored liquid and the bottom of the seal. 

Vapor-tight tank truck or vapor-tight railcar means a 

tank truck or railcar which has passed the vapor tightness 

test in §63.126(e). 

Vent stream, as used in the process vent provisions, 

means . x" gas stream discharged directly from an air 

oxidation process, reactor process, or distillation 

o r 

operation to the atmosphere er indirectly-^o the atmoGpheg< 

p rd d u.'e_£- ^coower-^j 

after diversion thr-"Tjh 'nrhar prnfiaar1 ri-irifl^n4- The vent 

stream excludes relief valve discharges and equipment leaks, 

but includes vents from product accumulator vessels. 

Volatile organic or VO refers to the portion of organic 

compounds (including both HAP and non-HAP organic compounds) 

in a wastewater stream that is measured by Method 25D, as 

found in 40 CFR 60, Appendix A. 

Volatile organic hazardous air pollutant or VOHAP means 

the volatile portion of an individually-speciated organic 

HAP in a wastewater stream or a residual that is measured by 

a combination of Method 25D and Method 18, as found in 

40 CFR 60, Appendix A. 

Waste management unit means any component, piece of 

equipment, structure, or transport mechanism used in 

conveying, storing, treating, or disposing of any waste, 

including a wastewater stream or a residual. Examples of 

waste management units include wastewater tanks, air 

^ 

352 
P.49 

I (1) Keep an up-to-date, readily accessible record of 

^c^X the data in paragraphs (3) (1) , (3) (ii) , (3) (in) , or (3) (iv) 

k ^v ^r of this section, and n 

5 * 

Ss.S 

< U-^ y 

(2) Include the data in the report of the initial 

performance test required under §63.7 of Subpart A and \\^ . \a~X 

_c-o 

§63.103 of Subpart F. 

(3) The same data shall be submitted in the reports of 

all subsequently required performance tests where either the 

emission control efficiency of a combustion device, the 

outlet concentration of organic HAP or TOC (determined as 

specified under §63.116), or the TRE index value of the vent 

stream from a recovery system is determined. 

(i) Where an owner or operator seeks to demonstrate 

compliance with the use of a combustion device to achieve a 

98 weight percent reduction in organic HAP or an organic HAP 

concentration of 20 parts per million by volume, as 

specified in §63.113(a)(2) the following shall be reported: 

(A) The parameters for incinerators, catalytic 

incinerators, boilers or process heaters specified in 

Table 3, and averaged over the same time period of the 

performance testing, and for a halogenated process vent 

stream the parameters specified for scrubbers in Table 3. 

(B) For an incinerator, the percent reduction of 

organic HAP or TOC determined as specified in §63.116(c) 

achieved by the incinerator, or the concentration of organic 

384