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OAR Box 1875 

Prepped by Ollie Stewart 

Document Number: 

10) ll-E-28 

Docket Number: 

A-90-19 

Printed 12/1/200811:12:44 AM Sheet 10 of 86 
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'y\ DEC \ 8 1992 

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A-90-19 

ll-E-28 

MEETING NOTES 

TO: 

FROM: 

MEETING DATE: 

SUBJECT: 

PARTICIPANTS: 

Jan Meyer, EPA/SDB 

Tracy Gionfriddo, Radian 

October 22, 1991 

Applicability of the HON 

Jan Meyer, EPA/SDB; Bob Rosensteel, EPA/CPB; Les 

Evans, EPA/CPB; David Gustafson, DOW/CMA; Mike 

Pope, DOW; Chuck Malloch, Monsanto; Vivian 

Mclntyre, Eastman Chemicals; Tom Kittleman, Co. 

DuPont/CMA; Amy Meyers, CMA; Brian Taranto, Exxon; 

Melvin Keener, BP 

APPLICABILITY OF THE HON 

Purpose 

The purpose of this meeting was to discuss how to define 

applicability of the HON. CMA is very interested in making sure 

that the owners and operators of process units affected by the 

HON as defined in the Source Category List, will be able to 

identify themselves. 

Outcome 

The CMA recommended determining whether a process unit is 

subject to the HON based on its primary product. There appear to 

be three possible methods to identify the primary product of a 

process. They are: 1) nominal sales value; 2) greatest 

production or mass output based on design capacity; and 3) 6-

digit SIC codes. Three CMA members participating in the 

conference call agreed to evaluate several processes at their 

facilities using these three methods and to determine if the 

results (identification of primary product) were consistent among 
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RADIAN 

ctiPOiario N 

the methods. Results of the evaluations will be sent to Amy 

Meyers (CMA) by October 30, and to EPA by November 1. 

Brief Meeting Summary 

Jan opened the meeting noting that for the HON, EPA is 

considering a definition of source that encompasses all SOCMI 

units in a contiguous area under common control. Emission points 

(i.e., continuous process vents, storage vessels, transfer 

operations, wastewater and equipment leaks) within the SOCMI 

units will be considered subject to the standard and would have 

to be evaluated to determine applicability of control 

requirements. The focus of the work on the database has been on 

process equipment trains designed and built to produce a product 

or range of products and not incidental production in a non-SOCMI 

process (e.g., fiber manufacturing). 

Members of CMA seemed to understand the intent of the HON 

but are concerned that unclear terminology may result in 

enforcement agencies applying the rule to processes that were not 

intended to be covered. Most of the meeting was spent discussing 

example production processes whose characteristics made it 

unclear whether or not they would be subject to the HON 

(Attachments 1 and 2). Brian Taranto (CMA) had some specific 

examples of polymer processes which produced streams containing 

SOCMI chemicals. Although these chemicals might be recycled, 

reclaimed, or sold, their production was not the purpose of the 

process unit in question—its purpose was the production of 

polymers. CMA is concerned that a broad definition of 

"production" would cause this unit to be subject to the HON. The 

EPA team explained that the HON is not intended to cover such 

processes whose primary purpose is the production of a non-SOCMI 

product. This unit would probably be covered under the polymers 

rule. After reviewing Mr. Taranto's other example processes, EPA 

said that their preliminary thoughts were that none of those 

example processes would be covered by the HON. 

Chuck Malloch (CMA) asked about a pesticide process whose 

intermediate steps produced SOCMI chemicals. He said that for 
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water regulations, this would be considered a pesticide unit. He 

would like to keep the same approach for HON. 

The EPA team recognized that there is potential for 

confusion and lack of clarity for such units and requested 

suggestions on how to unambiguously define principal product. 

Discussion turned toward methods for determining the primary 

product of a process; The first suggestion was to have industry 

declare a 6-digit SIC code for each process unit. Each unit 

would be regulated under that SIC code for all MACT rules. EPA 

asked what advantage a 6 digit SIC code had over the Source 

Category list. The reply from CMA was that the SIC code would 

determine the primary product. 

Again, the question became how to determine the primary 

product so that the correct SIC code could be assigned. Two 

other suggestions for determining the primary product were 1) 

the chemical with the highest nominal sales value and 2) the 

chemical with the largest mass output based on design capacity. 

Brian Taranto (Exxon, CMA), Chuck Malloch (Monsanto, CMA), David 

Gustafson (DOW), and Tom Kittleman (DuPont, CMA) agreed to 

evaluate several processes at their facilities using the three 

suggested methods for determining primary product (i.e., SIC 

code, sales value, mass output). The purpose of the analysis was 

to compare the results of the three methods with each unit's 

primary product and the source category list. Another objective 

was to determine if any unforeseen problems arise with any of the 

methods. The CMA members agreed to provide their results to Amy 

Meyers (CMA) by October 30, 1991, and Ms. Meyers would send them 

to EPA by November 1, 1991. The results will be discussed at the 

next meeting which will be held on November 6, 1991 at 1:30 or 

2:00 p.m. The location for the meeting was not decided upon but 

may be Washington, DC or Durham, North Carolina. 

Next meeting: November 6 at 1:30 or 2:00.