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OAR Box 1706 

Prepped by Ollie Stewart 

Document Number: 

48) IV-E-8 

Docket Number: 

A-98-13 

Printed 10/8/2008 10:25:09 AM Sheet 48 of 142 
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AUG - ,( pnn3 

MEMORANDUM 

Subject: Meeting Minutes for the May 22,2003, Meeting EPA and the American Chemistry 

Council (ACC) - OLD MACT Rule, 10:00-11:30 am 

From: K.C. Hustvedt 

U.S. EPA/OAQPS/ESD 

To: Air and Radiation Docket 

Docket No. A-98-13 

Purpose of Meeting 

To present the OLD Technical Team's latest thinking on the direction ofthe final rule on the 

basis ofthe comments received on the proposed rule. 

Attendees 

Mr. K. C. Hustvedt, US EPA/OAQPS 

Ms. Martha Smith, US EPA/OAQPS 

Mr. Ken Meardon, MACTEC 

Mr. Robert Morehouse, Exxon/Mobil 

Mr. Ted Cromwell, ACC 

Ms. Tara Lanier, Ashland/Marathon 

Summarv of Discussion 

We first summarized the major items ofthe proposed rule and the direction that the EPA Staff 

was considering for the final rule based on the comments received and the re-analysis of the data base 

(see Attachment 1). 

Items covered included: 

• Wastes. ACC was concerned that we intended to include wastes as organic liquids. ACC 

noted that at larger facilities waste tanks are likely to be emptied into tank trucks 

through a loading rack, whereas at smaller facilities waste tanks are likely to be emptied into 

tank trucks using a pump hook-up directly between the waste tank and the tank truck. EPA 

indicated that the coverage of wastes still needs to be clarified. 

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• List of HAP. EPA indicated that the Table 1 HAP in the proposed rule now included all 98 

HAP (including the six glycol ethers) identified in the Technical Support Document (TSD) as 

being in OLD liquids (see Attachment 2). ACC expressed concern about how the vapor 

pressures were calculated, especially that the vapor pressure for styrene appeared to be too 

high. 

• Equipment leak components associated with pipelines. ACC was concerned that these 

components would be picked up by the rule even when the pipeline went directly to a nonOLD storage tank. EPA indicated that the intention in the final rule was not to cover such 

components unless the pipeline was associated with an OLD storage tank. EPA indicated 

that the intent ofthe rule is to "catch" tanks and racks and associated equipment not covered 

by other 40 CFR part 63 rules. 

• Storage tanks (Attachment 3). Current staff recommendation are controls for tanks greater 

than 40,000 gallon capacity at any partial HAP vapor pressure and control for tanks with 

capacities between 20,000 gallons and 40,000 gallons storing liquids with at least 1.9 psia 

partial HAP vapor pressure. Current staff recommendations also include a no emission 

reduction floor for tanks with capacities less than 20,000 gallons. ACC was concerned that 

single tanks were apparently setting new source floors for a number of tank capacity and 

vapor pressure ranges and suggested that EPA re-examine these tanks (e.g., to ensure that 

none of them were operating on a temporary basis as might occur in an "overflow" situation). 

We agreed to send ACC the database and put it into the record. 

• Transfer Racks (Attachment 4). Current staff recommendations is control for existing racks at 

facilities with outgoing OLD liquid transfer between 800,000 and 7 million gallons if the liquid 

is at least 98% HAP and for existing racks at facilities with outgoing OLD liquid transfer of 7 

million gallons or more at any HAP concentration (greater than 0.1 weight percent). New 

source MACT would require controls at all size facilities but with different minimum HAP 

percentages (less than 800,000 gallons and 5% HAP or greater; 800,000 to 7 million gallons 

and 1% HAP or greater; 7 million gallons or greater and 0.1% HAP or greater). It was noted 

that only racks transferring OLD liquids would be required to be controlled under the rule and 

that only the amount of outgoing OLD liquid would be used to determine the facility 

throughput amount. 

• Storage of oil at oil and gas sites. ACC asked if tanks storing crude oil at oil and gas sites 

were covered by the OLD rule. EPA indicated that if the storage tanks were after transfer 

custody, they would be covered. It was noted, however, that there can be 

• several points of transfer custody and that the final rule would have to clarify which point of 

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3 

transfer custody is the relevant one. EPA did note that crude oil pipeline stations are covered 

by the OLD rule and that crude oil tanks at such sites would therefore also be subject to the 

OLD rule. EPA also noted that it is not the intent ofthe OLD rule to cover oil and gas 

exploration facilities. 

Q Containers. EPA indicated that the final rule might have a requirement for the loading of large 

containers (55 gallons or larger) for new sources. ACC expressed concern about the 

potential impact on the paint and coating industry. EPA indicated that those facilities should 

be subject to the MON's paint and coating regulation. 

• Equipment to be included in the affected source. EPA indicated that in order to be included in 

the affected source, the equipment (tanks, racks, and equipment leak components) had to 

handle an organic liquid, which is currently being considered as a liquid containing at least 0.1 

weight percent HAP and with a total vapor pressure ofat least 0.1 psia. Equipment subject 

to the MON is not part ofthe OLD affected source. ACC asked if it was still the intent ofthe 

OLD rule to only require control of loading (outgoing) racks and not unloading (incoming 

racks), but that both outgoing and incoming racks would still be part ofthe affected source. 

EPA indicated that this was still the intention. 

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ATTACHMENT 1 

OLD MACT STAFF RECOMMENDATIONS 

May 21, 2003 

f 
OLD MACT Staff Recommendations 

May 21, 2003 

TOPIC PROPOSAL DRAFT FINAL RULE 

Facility applicability 

Organic liquid 

throughput cutoff 

Facilities with less than 7.29 million gallons of Organic 

Liquids exempt 

No facility-wide throughput cutoff 

Definition of Organic Liquid 

List of organic HAP 

in Table 1 of rule 

Listed 69 HAP List all 98 HAP identified in the OLD survey (with individual 

glycol ethers identified) 

V\ 

Organic Liquid 

definition 

Liquids containing 5 or more weight percent ofthe 

Table 1 HAP 

Liquids containing 0.1 or more weight percent ofthe Table 1 

HAP and with total organic vapor pressures greater than 0.1 psi. 

Considering approaches to justify raising the weight percent 

HAP cutoff to 1 to 5 percent 

"Black Oil" 

Exemption for 

Crude Oil 

Exempted Black Oil, which is crude oil less than an 

API gravity (40°) and gas to oil ratio (31 fVVgal) cutoffs 

as defined in the Oil and Gas MACT 

Black Oil definition is deleted. Crude oil is subject to the same 

requirements as other organic liquids 

Emission Point Standards 

Emission points 

subject to other 

MACT standards 

Not clear. Excluded either emission points subject to 

or controlled by another MACT 

Emission points subject to another MACT standard would be 

excluded 

Storage tanks Tanks subject to control based on the HON vapor 

pressure and size cutoffs and on total vapor pressure of 

stored liquid 

Tanks subject to control based on size and partial pressure of 

the HAP. Values determined by OLD database and beyond 

floor considerations 

Transfer Racks Loading positions with annual organic liquid transfers 

of 3.12 million gallons or more subject to 95 percent 

control requirement 

Loading racks subject to control based on facility rack 

throughput and HAP content. Values determined by the OLD 

database and beyond floor considerations. Affected racks 

subject to 98 percent emission reduction requirement. 

TJ 
TOPIC 

Equipment Leaks 

Containers 

Wastewater 

PROPOSAL 

Reference existing MACT standards to apply to 

equipment with 5 percent or greater Table 1 HAP 

No additional requirements 

No additional requirements 

DRAFT FINAL RULE 

No change 

Existing - no change 

New - control large containers 

No change 

<r» 

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ATTACHMENT 2 

OLD HAP by VAPOR PRESSURE 

1 
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ATTACHMENT 2 

OLD HAP by VAPOR PRESSURE 

« 
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OLD HAP by Vapor Pressure 

HAP Compound 

Methyl chloride (Chloromethane) 

Fonnaldehyde 

Vinyl chloride 

1,3-Butadiene 

Ethylene oxide 

Ethyl chloride (Chloroethane) 

Hydrogen fluoride (Hydrofluoric acid) 

Acetaldehyde 

Vinylidene chloride 

Ethylidene dichloride 

Propylene oxide 

Methylene chloride 

Allyl chloride 

Propionaldehyde 

Chloroprene 

Acrolein 

Chloroform 

Hydrochloric acid 

Methyl tert butyl ether 

1,2-Epoxybutane 

1,1-Dimethyl hydrazine 

Hexane 

Metiiyl chloroform 

Vinyl acetate 

Acrylonitrile 

Methanol 

Carbon tetrachloride 

Methyl ethyl ketone 

Benzene 

Acetonitrile 

Ethylene dichloride 

Chlorine 

Glycol ethers 

Trichloroethylene 

Triethylamine 

Methyl hydrazine 

1,3-Dichloropropene 

2,2,4-Trimethylpentane 

Ethyl acrylate 

Propylene dichloride 

amber 

74873 

50000 

75014 

106990 

75218 

75003 

7664393 

75070 

75354 

75343 

75569 

75092 

107051 

123386 

126998 

107028 

67663 

7647010 

1634044 

106887 

57147 

110543 

71556 

108054 

107131 

67561 

56235 

78933 

71432 

75058 

107062 

7782505 

Glycol 

79016 

121448 

60344 

542756 

540841 

140885 

78875 

Vapor Pressure 

(psi) 

74.060 

67.679 

51.436 

40.607 

24.171 

23.204 

17.403 

16.823 

12.182 

11.428 

10.152 

8.470 

7.116 

5.801 

5.279 

4.718 

4.022 

3.674 

3.596 

3.481 

3.036 

2.901 

2.378 

2.224 

2.204 

2.204 

2.185 

1.934 

1.842 

1.740 

1.547 

1.496 

1.470 

1.450 

1.104 

0.959 

0.831 

0.785 

0.773 

0.773 
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Methyl methacrylate 

1,4-Dioxane (1,4-Diethhyleneoxide) 

Toluene 

1,1,2-Trichloroethane 

Tetrachloroethylene 

Epichlorohydrin 

Methyl isobutyl ketone 

Hydrazine 

Chlorobenzene 

Ethylene dibromide 

Ethyl benzene 

Titanium tetrachloride 

p-Xylenes 

Xylenes (isomers and mixture) 

m-Xylenes 

Styrene 

o-Xylenes 

1,1,2,2-Tetrachloroethane 

Acrylic acid 

Cumene 

Dimethyl fprmamide 

Hexachloroethane 

Diethanolamine 

N,N-Diethyl aniline 

Aniline 

Isophorone 

Acetophenone 

Phenol 

Cresols/Cresylic acid 

Nitrobenzene 

Styrene oxide 

o-Cresol 

Maleic anhydride 

o-Toluidine 

Naphthalene 

1,2,4-Trichlorobenzene 

Chloroaeetic acid 

m-Cresol 

p-Cresol 

Quinoline 

Ethylene glycol 

2,4-Toluene diisocyanate 

umbe r 

80626 

123911 

108883 

79005 

127184 

106898 

108101 

302012 

108907 

106934 

100414 

7550450 

106423 

1330207 

108383 

100425 

95476 

79345 

79107 

98828 

68122 

67721 

111422 

121697 

62533 

78591 

98862 

108952 

1319773 

98953 

96093 

95487 

108316 

95534 

91203 

120821 

79118 

108394 

106445 

91225 

107211 

584849 

\ apor Pii 

(psi) 

0.754 

0.715 

0.580 

0.483 

0.367 

0.329 

0.304 

0.278 

0.228 

0.228 

0.193 

0.193 

0.184 

0.164 

0.155 

0.141 

0.135 

0.126 

0.101 

0.089 

0.077 

0.013 

0.011 

0.010 

0,01 

0.008 

0.008 

0.007 

0.006 

0.006 

0.006 

0.0' 

0.005 

0.005 

0.004 

0.003 

0.003 

0.002 

0.002 

0.002 

0.002 

0.002 

to 
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IIAP Compound Vapor Pressure 

Diethyl sulfate 

Biphenyl 

Acrylamide 

2,4-D, salts and esters 

Dibenzofurans 

Phthalic anhydride 

Iroquinone 

Dibutylphthalate 

Methylene diphenyl diisocyanate 

4,4'-Methylenedianiline 

64675 

92524 

79061 

94757 

132649 

85449 

123319 

84742 

101688 

101779 

0.0i 

0.000 

0.000 

0.000 

0.000 

0.000 

0.000 

0.01 

0.000 

0.000 

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ATTACHMENT 3 

STORAGE TANKS PROMULGATION FLOOR ANALYSIS 

May 21, 2003 

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STORAGE TANKS PROMULGATION FLOOR ANALYSIS 

May 21, 2003 

Capacity 

(gallons) 

<5,000 

5,000 to <10,000 

10,000 to <20,000 

20,000 to <40,000 

>40,000 

Vapor Pressure Range 

(partial pressure of HAP) 

all 

<0.1 

0.1 to<4.0 

>4.0 

<0.1 

0.1 to<4.0 

>4.0 

O.I 

0.1 to <1.9 

1.9to<4.0 

>4.0 

<0.1 

0.1to<0.75 

0.75 to <1.9 

1.9to<4.0 

>4.0 

Counts 

Controlled 

0 

0 

2 

1 

0 

2 

1 

1 

1 

0 

2 

93 

158 

46 

112 

15 

Total 

31 

18 

19 

2 

10 

26 

2 

13 

16 

7 

2 

188 

199 

76 

116 

19 

t l 
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ATTACHMENT 4 

TABLE 1. THROUGHPUT AND HAP CONTENT RANGES - TRANSFER RACKS 

(May 21, 2003) 

/t 
Table 1. Throughput and HAP Content Ranges - Transfer Racks (May 21, 2003) 

Transfer 

Operation 

Annual 

Throughput 

(gallons) 

<800,000 

800,000 to 

7million 

> 7 million 

<1%HAP 

Controlled 

0 

0 

3 

Total 

0 

2 

6 

1 to <5% HAP 

Controlled 

0 

1 

4 

Total 

2 

4 

5 

5 to <25% HAP 

Controlled 

2 

2 

6 

Total 

5 

8 

13 

25 to <50% HAP 

Controlled 

1 

0 

2 

Total 

1 

3 

4 

50 to <75% HAP 

Controlled 

0 

1 

4 

Total 

0 

1 

4 

75 to <98% HAP 

Controlled 

0 

0 

5 

Total 

3 

5 

7 

>98% 

Controlled 

1 

8 

29 

Total 

4 

28 

39 

This analysis excludes liquids with total vapor pressures less than 0.1 psia and with HAP contents less than 0.1 wt %. Some liquids are excluded based 

on the total vapor pressure exclusion, but none on the HAP content exclusion (i.e., all are above 0.1 wt %). 

VN