p.1 

OAR Box 1672 

Prepped by Charmelle Mathews 

DocumentNumber: 

ll-D-34 

Docket Number: 

A-98-13 

Printed 9/30/2008 11:01:01 AM Sheet 99 of 132 
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FiU SuPY 

Voice: 732 - 326 - 0400 

P.O. Box 85 —2a_.^ ^ Fax:732-326-0424 

Woodbridge, NJ 07095 RRo y EnterprjseS | L L c < http^/Www.rroysp^aol.com 

A 98 13 

May 22f 1998 ll-D-^34 

Hr. Stephen Shedd 

'•j • - • - -

Emission Standards Division(MD-13) _ 

Office of Air Quality Planning and Standards * 

U.S. Environmental Protection Agency > ! _ 

Research Triangle Park, NC 27711 ; 

RE; Organic Liquid Distribution (OLD. Data Request' 

Dear Sir; 

The enclosed letter and survey documentation for Powell 

Duffryn Terminals has come to me. 

Please be advised that Powell Duffryn Terminals (PDT) no 

longer owns or operates any facilities in the U.S.A. There are no 

Powell Duffryn Terminals employees. I have been retained to assist 

PDT's parent company (Powell Duffryn pic, based in the U.K.) with 

certain "wind-down" activities relating to the sales. 

At one time PDT owned and operated three bulk liquid "for 

hire" storage and distribution facilities (SIC 4226). I have listed 

the location, date of sale, and the purchaser of each facility: 

Location Date of Sale Purchaser 

Savannah,GA October 31,1996 S.T. Services 

Bayonne, NJ February 14, 1997 I.M.T.T. 

Lemont, IL August 11, 1997 I.M.T.T. 

Each facility was sold as an "operating, open for business" 

facility. All records relating to data requested by the captioned 

survey were passed on to the purchasers. Accordingly, no one is 

able to respond to the survey for PDT. 

Sincerely, 

Ronald Spragui 
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!-***% 

APR 2 9 1998 

Anthony G. Tucker, President

 AW QU*-TY PUNNING 

Powell Duffiyn Teiroinals, Inc. ""STANDARDS 

Post Office Box 283 

2 Commerce Street 

Bayonne, New Jersey 07002 

Dear Mr. Tucker: 

The U.S. Environmental Protection Agency (EPA) is compiling detailed information on 

sources and quantities of hazardous air pollutant (HAP) emissions and control techniques. This 

information will be used in setting national emission standards for hazardous air pollutants 

(NESHAP) under section 112 ofthe Clean Air Act (CAA), as amended in 1990. The standards 

will apply to non-gasoline handling operations at both existing and new organic liquids 

distribution facilities. These standards are scheduled to be promulgated by November 2000. The 

EPA's initial steps for this endeavor include the collection of information on HAP emissions and 

emission reduction techniques in the organic liquids distribution industry. Your assistance in 

providing information is critical in developing a regulation that is realistic and workable, as well as 

protective ofthe environment. 

Enclosure 1 itemizes the information that you are requested to submit. The EPA will use 

the information to quantify HAP emissions; define the current status of emission control; and 

assess the environmental, energy, and economic impacts of installing and operating feasible 

emission control techniques. The information needed for regulatory development is contained in 

the information collection form approved by the Office of Management and Budget (OMB No. 

2060-0239). We are sensitive to die amount of labor required to respond to this request; 

therefore, to minimize demands on your time, information specific to the organic liquids . 

distribution industry has been extracted from OMB form No. 2060-0239 and formatted to make it 

more relevant to this industry. The EPA consulted industry representatives from both organic 

liquids distribution companies and trade organizations, and their comments improved the 

instructions for this survey as well as its overall focus. Enclosure 1 is the reformatted version of 

the OMB approved form and contains detailed instructions. The OMB approved form is available 

upon request. 

The authority for the EPA's information gathering is included in section 114 ofthe CAA 

(42 U.S.C. 7414). Enclosure 2 contains a summary of this authority. You should also be aware 

that any failure to comply with our request is a violation of section 114 and as such is subject to 

Intern*! Addrat* (URL),* http:ZAwww.spa.gov 

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enforcement under section 113 (specifically, section 113(dXl)(B) ofthe CAA, which provides 

civil penalties of up to $25,000 per day of violation). If you believe that disclosure of any 

specific information that you submit would reveal a trade secret, clearly identify such 

information as discussed in the enclosure. Refer to enclosure 2 for the information the EPA may 

require, at a later time, to support your confidentiality claims. Any information determined to 

constitute a trade secret will be protected under 18 U.S.C. 1905. If no claim of confidentiality 

accompanies the information when it is received by the EPA, it may be made available to the 

public by the EPA without further notice (40 CFR part 2.203, September 1,1976). Section 114 

ofthe CAA exempts emission data from claims of confidentiality and emission data collected 

may be made available to the public. A clarification of what the EPA considers to be emission 

data is contained in enclosure 3. 

As noted in enclosure 4, we have designated Pacific Environmental Services, Inc. (PES) 

as an authorized representative ofthe EPA. Therefore, PES has the rights discussed above and in 

enclosure 2. As an authorized representative ofthe EPA, PES is subject to the provisions of 

42 U.S.C. 7414(c) respecting confidentiality of methods or processes entitled to protection as 

trade secrets. The PES contract with the EPA is No. 68D60013. 

Enclosure 5 summarizes Agency and Emission Standards Division policies and 

procedures for handling privileged information and describes EPA contractor commitments and 

procedures for use of confidential materials. It is the EPA's policy that compliance by an 

authorized representative with the requirements detailed in enclosure 5 provides sufficient 

protection for the rights of submitters of privileged information. 

We request that you return the completed information request by July 8,1998. If you 

have any questions regarding this request, please contact Mr. Stephen Shedd of my staff at 

(919) 541-5397, or E-mail address: shedd.steve@epa.gov. 

Sincerely, 

Bruce C. Jordan 

Director 

Emission Standards Division 

5 Enclosures 

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