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OAR Box 1669 

Prepped by Charmelle Mathews 

Document Number: 

$-£6) II-E-18 

Docket Number: 

A-98-13 

Printed 9/23/2008 9:36:49 AM Sheet 86 of 110 
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A-^6-/3 

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Teleconference Report 

Organic Liquids Distribution NESHAP 

From: 

Date: 

Contact: 

Bernd Haneke, Pacific Environmental Services, Inc. (PES)^^ f 

August 25,1999 

Mr. Don Wang, EP Staff Engineer 

Company: Union Carbide Corporation, Charleston, West Virginia 

Telephone Number: 304/747-4924 

I. Participants 

Bernd Haneke, Pacific Environmental Services, Inc. 

Greg LaFlam, Pacific Environmental Services, Inc. 

Martha Smith, U.S. EPA, OAQPS/ESD/WCPG 

Don Wang, Union Carbide Corporation 

II. Teleconference Summary 

Don Wang had asked PES to call him to clarify questions related to the Organic Liquids 

Distribution (O.L.D.) NESHAP's Model Plants memo. PES and the EPA project lead, Martha 

Smith, called Mr. Wang on August 5,1999 to discuss and answer Mr. Wang's questions. 

Question/Comment 1: How were model plants developed? 

Mr. Wang was informed by the EPA project team that model plants were developed on the basis 

of information obtained from the O.L.D. data base. The model plants were developed on the 

basis of: 

1. Number of storage tanks, 

2. Storage tank throughput, 

3. Number of transfer racks and loading positions, 

4. Transfer rack throughput, 

5. Equipment numbers. 

An attempt was made to develop model plants for small, medium, and large facilities. Using this 

methodology, facilities were assigned to these categories for further analysis in support ofthe 

rule development. 
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Telecon Report 

Union Carbide Corporation 

Page 2 

Question/Comment 2: Cost effectiveness for small plants may not be very large. 

The EPA/PES project team acknowledged this statement and informed Mr. Wang that an 

economic analysis was being performed by an EPA contractor. The economic analysis has not 

been completed, therefore information is not obtainable at this time. 

Question/Comment 3: Average HAP Percentages in O.L.D. Liquids 

Mr. Wang inquired how the average HAP percentages presented in Table 3 ofthe Model Plants 

memo were developed. The EPA/PES project team informed him that the survey had requested 

HAP weight percents in both liquids and their vapors. In most cases the respondents did not 

provide the average vapor weight percents, so the average liquid weight percents were used in 

the emissions calculations. Mr. Wang suggested that the EPA/PES project team develop a 

simple spreadsheet, based upon Raoult's law, in which the vapor weight percents for various 

liquids are calculated. The EPA project team acknowledged this approach, and agreed to 

investigate it further. 

Question/Comment 4: Compressors 

In a previous telephone conversation, the EPA/PES project team had asked Union Carbide about 

the use of compressors in the O.L.D. industry. At that time, Union Carbide had responded that 

they do not use compressors to transfer liquids. Mr. Wang was asked again about his 

understanding ofthe use of compressors in the O.L.D. business, to which he answered that he 

was not aware that compressors were being used to transfer and distribute liquids. 

Questions/Comments submitted by John Soice of Union Carbide Corporation 

John Soice, Union Carbide Corporation, submitted to Mr. Wang various questions and 

observations pertaining to the Model Plants memo. Mr. Soice was not present at this 

teleconference, so his comments and questions were delivered by Mr. Wang. 

Question/Observation 1: 

Mr. Soice observed that the equipment counts for flanges in SIC code 28 appear to be lower than 

would be expected for this industry. The EPA/PES project team discussed this at length with 

Mr. Wang and it was decided that Union Carbide Corporation would re-evaluate its equipment 

count numbers. It was also suggested that some facilities may have erroneously reported their 

equipment counts (see Attachment 1). The EPA/PES project team informed Mr. Wang that the 

equipment counts for many facilities appeared to be either very large or very small. 

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Telecon Report 

Union Carbide Corporation 

Page 3 

Question/Observation 2: 

Mr. Soice observed that the O.L.D. survey did not ask for storage tank dimensions, and that the 

Model Plants memo provides storage tank dimensions in Table 4. Mr. Wang stated that storage 

tank heights and diameters were important in determining emissions, and that Mr. Soice had 

commented that it would have been useful for the EPA to request this information. 

The EPA/PES project team responded by stating that it had developed model storage tanks which 

were programmed into Tanks3.1 software to quantify emissions. Furthermore, they 

acknowledged Union Carbide Corporation's opinion that requesting storage tank dimensions 

would have been useful. 

Question/Observation 3: 

On behalf of Mr. Soice, Mr. Wang requested to know if transfer rack and storage tank 

throughputs had been combined. The EPA/PES project team responded that in most surveys, the 

transfer rack and storage tank volumes did not appear equal to each other. Therefore, these were 

analyzed separately. 

Question/Observation 4: 

Mr. Wang observed that pressure vessels were not being addressed in the Model Plants memo, and 

he requested to know ifthe EPA was going to regulate these in the O.L.D. NESHAP. The EPA/PES 

project team responded that to the best of its knowledge, the population of pressure vessels is quite 

low and they would not have significant emissions that would warrant control. 

Mr. Wang offered to send the EPA/PES project team a memorandum addressing pressure vessels 

which he had sent to Steve Shed earlier in the project. The EPA/PES project team agreed that 

this would be useful information (see Attachment 2). 

Question/Comment 5: 

Mr. Wang pointed out an anomaly in Table 2 ofthe Model Plants memo. He stated that 

external/internal floating roof tanks were usually used to store higher vapor pressure liquids than 

fixed roof tanks. He observed that for SIC code 28 the average vapor pressure for liquids in 

internal floating roof tanks were lower than for fixed roof tanks. 

The EPA/PES project team acknowledged this anomaly and pointed out that vapor pressures by 

tank type were developed from the tank and liquid information reported in the survey responses. 

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Telecon Report 

Union Carbide Corporation 

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III. Action Items 

Mr. Wang offered to check the facility equipment counts submitted by Union Carbide 

Corporation. Furthermore, Mr.Wang offered to send the EPA/PES project team a memo which) 

he had sent to Steve Shedd at an earlier date. These were received following the telephone 

conversation and are included as Attachments 1 and 2. 

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ATTACHMENT 1 

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From: "Wang DL (Don)" <wangdl@ucarb.com> 

To: '"Haneke, Bernd", <bhaneke@rtp.pes.com>, 'I'LaFlam, Greg'" <glaflam@rtp.pes.com> 

Copies to: "Soice JR (John)" <soicejr@ucarb.com>, "Williams JB (Jim)" <williajb@ucarb.com>, 

"Yalcinkaya AP (Peri)" <yalcinap@ucarb.com>, "Pedraza JL (Luis)" 

<pedrazj l@ucarb.com> 

Subject: B-9-99 Connector Count Correction in Texas City OLD MACT ICR 

Date sent: Mon, 9 Aug 1999 10:51:18-0400 

Bernd/Greg: 

I checked Table 7 in the UCC OLD MACT ICR's submitted to EPA for Connector Counts and found that a few of 

our Texas City Units had not included connectors or the connector count did not appear correct. 

To correct this apparent anomaly in connector count, a best estimate 

has been provided based on the following assumptions: 

1. 4 connectors/valve, to account for the 2 connectors/valve plus 2 pipe connectors 

2. 2 connectors/pump 

3. 1 connector/PRV. 

4. 1 connector/sampling connection 

Based on the above assumption, please add the connector count below, 

that may be subject to OLD MACT, to the following Units: 

Texas City Marine Terminal 

Valves-112 ; Pumps - 2; PRV's - 2 

Connectors - 454 

Texas City Main Plant Olefins Unit 

Valves - 49; Pumps - 1; Sampling Conections - 1 

Connectors- 199 

Texas City Main Plant IPD Unit 

Valves-137; Pumps-3; Sampling Connections-4; PRV-1 

Connectors - 559 

Texas City Main Plant SVR Unit 

Valves-474; Pumps-3 ;PRV's-20 

Connectors - 1922 

Let me know if further information is required. 

Don Wang - Union Carbide Corporation 

E-Mail: wangdl@ucarb.com 

Bldg 2000/Rm 3429 

Phone: 304-747-4924 

iff 
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ATTACHMENT 2 

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From: "Wang DL (Don)" <wangdl@ucarb.com> 

To: "Haneke, Bernd'" <bhaneke@rtp.pes.com>, GLaFlam. Greg"' <glaflam@rtp.pes.com> 

Subject: Compressed Gas Storage in OLD MACT 

Date sent: Fri, 6 Aug 1999 07:04:03 -0500 

Bernd/Greg: See below for DLW/UCC opinion (in red) on compressed gas storage. This was lifted from my 

response to OLD MACT ICR Workshop questions. Let me know if further info is required. 

Don 

3. Compressed Gases. Does the survey cover material that are gases at 

standard conditions, but are compressed/cooled to be loaded as a liquid? 

Response: Gases containing HAP that are compressed to a liquid for storage/shipping/transfer purposes may have 

the potential for HAP emissions from equipment leaks. Ifthe liquid is a HAP or contains HAP, and the applicability 

criteria are satisfied (plant is a large emitter, it is a surveyed liquid, and the activity is not covered by another MACT 

rule), the operation should be reported on the survey. 

(Note to roundtable: The EPA wants to make an informed decision on this issue. It is not clear from the question what 

the issues and ramifications are and what the rationale would be for not obtaining this information.) 

DLW-NSPS subpart K and HON states that pressurized vessels designed to operate in excess of 15 psig with no 

release to atmosphere (except for emergencies) are excluded from the rule. AP-42 Section 7.1.1.6 (2/96) states that 

high pressure storage tanks (higher than 15 psig) can operate so that virtually no evaporative or working losses 

occur. It appears that storage vessels designed in this manner emit very little to the atmosphere as confirmed by the 

consistent inclusion ofthe exclusion for this design in the previous air rules. Rather than covering old ground, it is 

suggested that pressurized vessels designed in this manner also be excluded from the ICR. 

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