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OAR Box 1875 

Prepped by Ollie Stewart 

Document Number: 

12) ll-E-30 

Docket Number: 

A-90-19 

Printed 12/1/200811:12:44 AM Sheet 12 of 86 
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A-90-19 

ll-E-30 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 

Office of Air Quality Planning and Standards 

Research Triangle Park, North Carolina 27711 

FEB 6 I992 . !'.('• " v 

DEC I 8 B92 

MEMORANDUM ^-V. ._..;,;. 

SUBJECT: November 22, 1991 Meeting on Emissions Averaging 

FROM: Daphne L. McMurre_V^" 

TO: The Files 

On November 22, 1991, several members of the Office of Air 

Quality Planning and Standards (OAQPS) met with representatives 

of specific companies and industry groups. Table 1 provides a 

list of the those who attended the meeting and their 

affiliations. 

The topic of this meeting was the emissions averaging policy 

for the National Emission Standards for Hazardous Air Pollutants 

(NESHAP) for Source Categories: Synthetic Organic Chemical 

Manufacturing Industry (SOCMI) and Seven other Source Categories. 

This regulation is commonly known as the Hazardous Organic 

NESHAP, or HON. 

The emissions averaging policy for the HON had been 

described on November 19, 1991 at a meeting of the National Air 

Pollution Control Techniques Advisory Committee (NAPCTAC). 

Industry representatives used the November 22, 1991 meeting to 

ask more detailed questions about the policy described at the 

November 19 NAPCTAC meeting. Questions were asked on the 

following topics: (1) whether emissions averaging would place a 

cap on emissions; (2) how the emissions averaging policy would 

interface with operating permits; (3) the reasoning for increased 

reporting with emissions averaging; (4) the system for 

determining credits and debits, especially concerning actual vs. 

allowable emissions; (5) how short term and/or maintenance 

shutdowns should be handled for averaging; (6) managing mixed 

streams and interpollutant trades; (7) the rationale for having a 
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baseline date from which credits can be generated; and (8) the 

need for discount factors given the industry's perception that 

there is inherent conservatism in the HON. 

In addition to asking questions about the emissions 

averaging policy, the industry and OAQPS representatives 

discussed the possibility of applying the emissions averaging 

policy at an actual facility. It was agreed the OAQPS and the 

Chemical Manufacturers Association (CMA) would pursue such an 

example after the HON was proposed. 

Finally, the group discussed the need to encourage States to 

implement the emissions averaging component of the HON once it is 

promulgated. 

Following the meeting, Ms. Amy Myers, of the CMA, prepared 

and sent me a draft summary of the meeting. This draft summary 

is provided as an attachment to this memorandum. 

Attachment 
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TABLE 1 

Name Affiliation 

B. Beck 

M. Brien 

J. Dege 

L. Evans 

C. Freeberg 

I. Graly 

B. Jordan 

C. Malloch 

D. Markwordt 

V. Mclntire 

D. McMurrer 

N. Morrow 

R. Rosensteel 

R. Streiter 

J. Woolbert 

Mobil/API 

Amoco/API 

DuPont 

EPA 

Chevron/API 

Arco/API 

EPA 

Monsanto 

EPA 

Eastman Chemical 

EPA 

Exxon Chemical 

EPA 

API 

Texas Eastman 

N. Cookson 

A. Meyers, Staff Executive 

A. Stanley 

CMA 

CMA 

CMA 

API = American Petroleum Institut e 

CMA = Chemica l Manufacturers Associatio n 

EPA = Environmenta l Protectio n Agency 
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CH 

CHEMICAL MANUFACTURERS ASSOCIATION 

Meeting Between Representatives of 

EPA's Office of Air Quality Planning and Standards and 

The Chemical Manufacturers Association and API 

November 22, 1991 

TfTFTf TCTtTlTt'ttTtftTCT 

B. Beck 

M. Brien 

J. Dege 

L. Evans 

C. Freeberg 

I. Graly 

B. Jordan 

C. Malloch 

D. Markwordt 

V. Mclntire 

D. McMurrer 

N. Morrow 

R. Rosensteel 

R. Streiter 

J. Woolbert 

Mobil/API 

Amoco/API 

DuPont 

EPA 

Chevron/API 

Arco/API 

EPA 

Monsanto 

EPA 

Eastman Chemical 

EPA 

Exxon Chemical 

EPA 

API 

Texas Eastman 

N. Cookson 

A. Meyers, Staff Executive 

A. Stanley 

• •»•••••»••••••••••• • • • • • • j ^ _I__E- A J . • • • • • • • • -• •••>. • • • • • 

TfWTY^nrwTrTrjrTfTfTrwTrTnTTnA^ 

CMA 

CMA 

CMA 

1.0 The meeting was called to order at 10:00 a.m. The purpose of the 

meeting was to discuss emissions averaging. 

2.0 D. McMurrer of EPA stated that the meeting was to be focused on the 

HON and agreed to answer technical questions on the OAQPS Emissions 

Averaging Proposal. 

2.1 The question of whether emissions averaging would place an 

additional cap on emissions was raised and discussed. 

2.2 The question of how emissions averaging would interface with 

the permit program was raised and discussed. 

2.3 Industry members questioned the reasoning behind increased 

reporting for the emissions averaging program. 

2.4 Industry members requested further explanation of the system 

for determining debits and credits, and how this system handles 

actual vs. allowable emissions. 

2.5 Industry raised the question of how short term and/or 

maintenance shutdowns of averaged sources were to be handled. 

2501 M Street, NW Washington, DC 20037 202-887-1100 Telex 89617 (CMA WSH) 
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V* 

3.0 The group discussed how mixed streams and Interpollutant trading 

could be managed. 

4.0 The group discussed examples of emissions trading and agreed to 

pursue a detailed example at a chemical plant. 

5.0 The group discussed encouraging the states to implement emissions 

averaging. 

6.0 The group discussed the existence of a baseline and EPA's proposal 

to not allow credit for reductions made before the baseline date. 

8.0 The group discussed discounting factors and the built-in 

conservatism in MACT and emissions averaging. 

9.0 The meeting adjourned at 12:30 pm. 

Sincerely, 

Amy Meyers 

Manager, Air Programs 

cc: K. Bailey ,, 

N. Cookson H u 

B. Jordan 

D. McMurrer 

G. O'Dea 

R. Sigman 

A. Stanley