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OAR Box 1672 

Prepped by Charmelle Mathews 

Document Number: 

fipjrf) ll-C-32 

Docket Number: 

A-98-13 

Printed 9/30/2008 11:01:01 AM Sheet 61 of 132 
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A 98 1.3 

Date sent: Tue, 23 Jun 199815:51:35 -0400 

From: STEVE SHEDD <SHEDD.STEVE@epamail.epa.gov> 

Subject: Draft Responses to Major Questions Identified During ICR Workshop 

To: jacobsenje@alyeska-pipeline.com, rwhermanson@amoco.com, jbneville@aol, 

com@epamail.epa.gov, billnacd@aol.com, mullingsp@api.org, ritterk@api.org, 

hmielt@basf.com, pho@bryancavellp.com, 

Norman.L.Morrow@chemical.exxon.sprint.com, donna_h@deq.state.la.us, 

LMPLATT@dow.com, bill_r_beck@email.mobil.com, jestock@emcowheaton.com, 

joefed@emcowheaton.com, SHEDD.STEVE@epamail.epa.gov, 

SORRELS.LARRY@epamail.epa.gov, joelfazzio@imtt.com, ztcdcm@is.arco.com, 

nttc@juno.com, ted_cromwell@mail.cmahq.com, GRWilson@MaratnonOil.com, 

ddarling@paint.org, delmer.billings@rspa.dot.gov, bhaneke@rtp.pes.com, 

glaflam@rtp.pes.com, jlmcclure@shellus.com, degeja%csoc.lvs.dupont.com@smtp, 

wangdl@ucarb.com 

Note to OLD Roundtable Participants June 23,1998 

Re: Draft Responses to Major Questions Identified During ICR Workshop 

Below are draft responses to major questions that attendees of the 

ICR workshop identified as items needing clarification. Before, we 

send to all the receivers of the ICR. I would like your thoughts 

as part ofthe workgroup that helped develop the survey, so we can 

make an informed and correct decision on these matters. 

As noted on the attached I have questions for some of you. It was 

unclear to me at the workshop if attendees had real questions or 

concerns with these items or they were correctly just attempting to 

confirm their understandings or venting their frustrations to get 

this task completed. I would appreciate your thoughts on all the 

above. Also, this is a review draft for the roundtable review and 

correction, and please do not distribute outside our group until 

after we have had a chance to review and consider your comments. 

Due to the holidays, I would like any thoughts from you by next COB 

Monday, June 29,1998, so that we may send this out before the 4th 

of July. Thanks again for your continued interest and effort on 

this project and roundtable. 

'! 

Steve Shedd 

Roundtable Review Draft: June 23,1998 

QUESTIONS IDENTIFIED AT THE JUNE 3, 1998 ICR WORKSHOP IN HOUSTON, 

TEXAS 

1. Unloading and Intra-Site Transfers. Some respondents found the 

text and tables of the survey unclear and inconsistent on whether 

unloading equipment (racks, arms, pumps, etc.) used for incoming 

liquids are to be surveyed. Commentors questioned why the 

corresponding transfer rack should be surveyed, claiming that it is 

not an emission source. Other questioners asked whether liquid 

transfers within a plant site boundary should be included. 

Response: To fully understand the organic liquids distribution 

industry the EPA needs to have information on the volumes of liquids 

entering a facility, as well as the equipment leaks associated with 

Greg LaFlam - 1 - Tue, 4 Aug 1998 11:07:51 
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incoming liquid transfers. The liquid materials entering a 

distribution facility may generate emissions of organic HAP at 

loading racks, from transfer equipment components (equipment leaks), 

as well as storage tanks. Emission controls on these activities may 

include vapor balance, storage tank controls (for example, a floating 

roof or control device), or other measures. 

Several scenarios that commentors have asked to be clarified are: 

A. Pipeline transfers (into or out of plant site). Responses should 

include the on site equipment components involved in the transfer at 

the plant site. For this information, fill out Table 1 *Organic 

Liquids Handled and HAP Content,* Table 3 *Liquid Transfer 

Operations,* Table 7 'Equipment Leak Control Data,* and all other 

tables as appropriate. 

B. Tank truck/railcar unloading racks. Report these activities in 

Table 1 *Organic Liquids Handled and HAP Content,* Table 3 *Liquid 

Transfer Operations,* and Table 7 'Equipment Leak Control Data.* If 

a control device is used, fill out Table 9 *Air Pollution Control 

Parameters* and fill out all other tables as appropriate. 

C. Direct feed to a process. A scenario in which a rail car feeds 

directly into a process was presented to the EPA project team by an 

industry representative. If this process is not regulated by 

another MACT standard, it must be reported in the survey. Table 1 

*Organic Liquids Handled and HAP Content,* Table 3 'Transfer 

Operations, and Table 7 'Equipment Leak Control Data,* must be 

filled out. In Table 3, report the method of loading/unloading of 

organic liquids as OT (Other), and provide a brief description 

detailing the operation. Fill out any other tables within the ICR as 

appropriate. 

D. Intra-site transfers and storage. The question asked is whether 

the dedicated transfer and storage equipment between on-site process 

units need to be reported in this survey. Do not report that 

dedicated equipment. However, report any storage vessel or transfers 

used for distribution of surveyed liquids across the plant site 

boundary. Fill out all tables within the ICR as appropriate to 

provide the required information. 

2. Incoming fuels and other products stored and consumed on the plant 

site. Several workshop participants requested clarification on what 

would have to be reported for incoming fuels and other liquids which 

are stored and/or consumed on the plant site. 

Response: All incoming or outgoing HAP containing organic liquid 

distribution activities should be reported (unless they are 

non-surveyed liquids or controlled by other MACTs). This includes 

any fuels (non-gasolines), solvents, or feed stocks. Fill out all 

tables within the ICR as appropriate to provide the required 

information. [Note to roundtable: This was a bit confused at the 

workshop, but it is unclear as to the rational on why exempting any 

in or out distributed organic liquids. There seamed to be some 

underling concern on this issue, that was not presented at the 

workshop. Is there an issue here?] 

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. If the liquid is a HAP or contains 

Greg LaFlam - 2 - Tue, 4 Aug 1998 11:07:51 

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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.) 

4. Major/Non-Major Sources. Does the survey cover plant sites that 

exceed the 5/12.5 tons/year (tpy) criteria (actual emissions), but 

have previously received a non-major HAP source permit (less than 

10/25 tpy of potential to emit (PTE) HAP emissions)? 

Response: The Organic Liquids Distribution MACT survey was shorten to 

not include non-major sources. The criteria of actual emissions 

instead of PTE emissions was used to determine non-major sources to 

simplify the survey calculations and side-step many of the PTE 

issues. However, if the plant site has received an enforceable 

non-major source permit based on PTE of HAP, it does not need to 

respond to the survey, despite its actual emissions total being 

between the 5/12.5 tpy criteria for large emitters and the PTE 10/25 

tpy criteria for major sources. 

(Note to roundtable: Would this response undermine our original 

intention of obtaining information on smaller, borderline sources? 

Our 'transition* actual emission cutoffs of 5/12.5 tpy were meant to 

cover sources that have the potential to be major. Since the source 

has been permitted as a non-major based on its potential-to-emit 

(PTE) it seems unreasonable to not let them out of the survey.) 

5. Marine Un/Loading Operations. Are (a) unloading operations or (b) 

ballast water at marine vessel facilities covered in the survey? 

Response: (a) The Marine Vessel Loading MACT rule (40 CFR 63, 

subpart Y) does not regulate unloading (from the marine vessel onto 

the plant site). Therefore these operations should be reported in 

this survey, as instructed in LB above for trucks and railcars. 

Subpart Y also does not affect equipment components associated with 

liquid transfer operations in or out of a facility. Thus, reporting 

should include equipment counts and any LDAR activities (report in 

Table 7 'Equipment Leak Control Data*) in effect for the plant site 

(but not the marine vessel itself)- Furthermore, fill out all 

additional tables as appropriate. (Note to roundtable: In doing so, 

this may be the only reportable information for some standalone 

unloading facilities, is that a problem?) (b) In development of 

Subpart Y standard, it was decided that control of ballasting (the 

introduction of ballast water into a cargo tank of a tankship or 

oceangoing barge) was not warranted under the MACT program. Those 

ballasting operations do not need to be reported in the OLD survey. 

However, in cases where nonsegregated (contaminated) deballast water 

(is pumped from the tankship or oceangoing barge onto the plant site) 

is treated on site, it should be included in Table 4 *Wastewater Flow 

Rates and Drain Controls* and Table 5 *Wastewater Collection and 

Treatment Control.* (Note to roundtable: I am not sure of the need 

or ramifications here, I need some input!) 

6. Gas Plants. One commentor pointed out that the definition of 

custody transfer states that one point of custody transfer is the 

point at which natural gas enters a natural gas processing plant. Are 

such gas plants to be included in the OLD survey because they load 

products derived from natural gas into tank trucks? 

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Response: As noted in the instructions to the survey (I.B.2) this 

survey does not plan to cover natural gas facilities. Natural gas 

operations at gas plants fall into that statement and are currently 

being considered for control under the proposed Oil and Gas MACT, 

however if the product is a considered a natural gas liquid and is 

past the point of custody transfer then those distribution activities 

are not controlled by the Oil and Gas MACT and should be reported in 

this survey at facilities meeting the large emitting size criteria 

for this survey (I.A). 

(Note to roundtable: Is this expected to occur frequently at major 

source facilities? Is there a problem with reporting this 

information? Do gas plants distribute HAP liquids meeting our survey 

criteria?) 

7. Asphalt. Asphalt satisfies the 0.1 psia criterion at conditions of 

loading (275°F and sometimes with added solvent to facilitate 

transfer), and so could be considered a surveyed liquid. However, at 

ambient temperatures, the vapor pressure is well below the cutoff. Is 

asphalt then a surveyed liquid for this survey? Some workshop 

participants stated that there are no controls presently in effect for 

this operation, so the MACT regulation would not end up specifying a 

uncontrolled MACT control level for asphalt transfers, they also 

stated that Texas state rules exempt asphalt because the cutoff is 

based on standard conditions, not loading conditions. 

Response: If asphalt loadings.emit HAP and meet the survey criteria 

at loading conditions, they should be included in the reporting. 

(Note to roundtable: Would some facilities have to report solely 

because of their asphalt operations? Are we assured that the MACT 

floor is *no control*? Do States besides Texas also not control 

asphalt? This product ends up largely on roofs and roads, so 

uncontrolled emissions are a necessary consequence ofthe end-uses. 

We are not sure about the rationale for not reporting/controlling 

these sources and request your input on the issues involved.) 

8. Gasoline Additive Tanks. Gasoline additives are stored at bulk 

gasoline terminals in relatively small tanks (mostly below 5,000 

gallons), and have vapor pressures below about 0.25 psia (but over the 

0.1 psia cutoff in the survey). In addition, they are not distributed 

out of the plant site except as a component of the gasoline. If such 

additives are included, this would bring in many such terminals that 

would otherwise not have to report. Given these considerations, does 

the unloading and storage of these additives need to be reported? 

Response: Gasoline additives appear to meet the criteria for a 

surveyed liquid. For this reason, tanks of 5,000 gallons or greater 

should be included in the reporting (for any type of facility). 

(Note to roundtable: The issues are similar to those for asphalt. 

How many gasoline terminals would be pulled in due to additives 

unloading/storage? What is the likelihood of an uncontrolled MACT 

floor? What are the HAP contents of gasoline additives? We are not 

sure about the rationale for not reporting these sources, and request 

your input on the issues involved.) 

9. Liquid Property Parameters. Respondents were unclear as to whether 

annual average values of liquid properties (such as true vapor 

pressure and HAP content) should be used in deciding what to consider 

as a surveyed liquid and in filling out Table 1 (Organicliquids 

Handled and HAP Content) ofthe survey. They also stated that some 

liquids naturally vary in HAP content. One respondent commented that 

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specific products may at different times have noticeably different HAP 

contents. 

Response: The EPA believes that the points advanced by a commentor 

constitute an appropriate answer. The commentor suggested that for 

products with intentionally different characteristics, consider each 

as a separate liquid (and report separately the best representative 

values for each liquid). For specific products that are varied 

unintentionally over time, use annual average values. This approach 

should avoid the situation of some products jumping *into* and 'out 

of the survey, depending on which batch is considered. 

10. Correction/clarification on reporting HON regulated equipment. On 

page 5, section I.E.3 the first sentence incorrectly suggests the 

reporting of HON regulated equipment and not reporting requested data. 

The first sentence should read: 3. List in Table 2 all distribution 

storage vessels not regulated by the HON because they are part of a 

non-HON regulated process unit. We are requesting full reporting of 

non-HON regulated storage vessels. HON regulated storage vessels and 

transfers are requested to be shown in appropriate circumstances on 

plot plans, as discussed in the May 22 additional instructions. 

Stephen A. Shedd 

U.S.EPA (Mail Drop 13) 

Office of Air Quality Planning and Standards 

Research Triangle Park, NC 27711 

Voice: (919) 541-5397 

Fax:(919)541-0246 

E-mail: shedd.steve@epa.gov 

Greg LaFlam - 5 - Tue, 4 Aug 1998 11:07:52 

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