P.1 

OAR Box 1875 

Prepped by Ollie Stewart 

Document Number: 

30) ll-E-48 

Docket Number: 

A-90-19 

Printed 12/1/206811:12:45 AM Sheet 30 of 86 
P.2 

', * A-90-19 

ll-E-48 

DATE: July 22, 1992 

SUBJECT: Hazardous Organic NESHAP (HON) Meeting with State 

Representatives 

PLACE: Washington, D.C. - EPA Headquarters 

The following EPA personnel participated in a meeting with 

members of the National Governors Association's Air 

Implementation Task Force: William Rosenberg, Assistant 

Administrator for Air and Radiation; Bruce Jordan, Director of 

the Emissions Standards Division; and Jeff Clark, Office of the 

Director, Office of Air Quality Planning and Standards. Attached 

are materials either distributed or discussed at the meeting, 

including an agenda and an NGA Strategy to Discount Air Toxics 

Emission Credits for Emissions Averaging. 

Attachments: 3 

EPA J\\?y^^0Z0^ 

mgmll.memos.det 
P.3 

AGENDA 

1. UPDATE ON HON/STRATEGY 

2. DISCUSSION OF NEW SOURCE REVIEW PROGRAM 

3. DISCUSSION OF ECONOMIC INCENTIVE PROGRAMS 

4. DISCUSSION OF YOC BANKING AND TRADING 

5. IMPLEMENTATION STRATEGY/FUTURE ISSUES FOR 

COMMISSIONER INVOLVEMENT 
P.4 

NAHONAL 

GOVERNORS 

ASSOCIATION 

John Ashcroft 

Governor of Missouri 

Chairman 

Roy Romer 

Governor of Colorado 

Vice Chairman 

Raymond C. Scheppach 

Executive Director 

Hall of the States 

444 North Capitol Street 

Washington, D.C. iOOOI-157: 

Telephone (202) 624-5300 

••*• • 

**** * 

July 21, 1992 

TO: Air Implementation Task Force 

FROM: Heidi Sno<J^4-vvfin~> 

RE: HON Workgroup Activities 

On July 20 Tad Aburn, Karen Olson, Bill 0'Sullivan and I had a 

conference call to discuss the discount factor for emissions 

averaging under the HON. The four of us agreed to put forth the 

attached discount factor proposal for your review. 

As indicated, the system applies a discount factor based upon 

whether use of the HAP is eliminated and how emission reduction 

credits are quantified. In addition, given state experience with 

emission modelling, the group felt that averaging should be used to 

overcontrol emissions from units with shorter effective stack 

heights. The group also agreed that wastewater emissions were very 

similar to fugitive emissions, and since fugitive emissions are 

excluded from the averaging system, wastewater should be treated 

likewise. Relative impacts for emission averages were calculated by 

Karen Olson to address concerns about dispersion rates and ability 

to predict emissions from various source types. Results of these 

calculations are attached. 

Please review the attached proposal and let ae know if yow have any 

objections to presenting it to BPA toamrrow during the Booting with 

Bill Rosenberg. I can be contacted at 202/624-5384. 
P.5 

SEM ftY^-JQEFE •21-32 1147AM : AIR ULAL1TV REC- :u26247o»i0:= 2' 4 

Scott A. vVeJner 

Commissioner 

TO: 

FROM: 

Stale of New Jersey 

Department of Environmental Protective <bid Energy 

Air Quality Regulation Program 

CN027 

Trenton. NJ 08625-0027 

July 21, 1992 

MEMORANDU M 

Air Implementation Task Force HON Workgroup 

Scott Weiner, Commissioner, NJDEPE 

Ken Alkema, Executive Director, Utah Division of 

Environmental Health 

Tad Aburn, Maryland Air Management Division 

Karen Olsen, Texas Air Control Board 

Don Theiler Wisconsin Air Management Bureau 

(STAPPA representative) 

Barbara Kwett, Mass. DEP 

Bill Becker/Mary Sullivan Douglas, STAPPA/ALAPCO 

Heidi Snow, NOA 

William O'SuUivan, NJDEP 

William O Sullivan. P.E 

Administrator 

SUBJECT: Strategy to Discount Air Toxics Emission Credits 

tor Emission Averaging 

Attached is a revised strategy as result of the 7/20 conference call between Karen 

Olsen, Tad Aburn, Bill O'SuUivan and Heidi Snow. 

I recommend that this strategy be shared with Bruce Jordan of EPA at the 7/22 NOA 

meeting and discussed with Bill Rosenberg of EPA at che 7/27 NGA meeting. 

This can be characterized as a common sense strategy, based on technical 

considerations, but simple enough to be worlcable and predictable. Tlic most controversial 

aspects of the recommendation are the "incentive to overcontrol short stacks" and the 

disallowance of credits for wastewater treatment over control. 

WOS/df 

Attachment 

c: Assistant Commissioner Weingart 

Director Wittenberg 

Assistant Director Elston 

Joann Held 

Mtw/«n*y M t/t Ctfutl Oppor*jnlty tJnptoyw 

tecydetf Nper 
5C.N 1 .Dl ZfJuLn.. . i - J _ i t •* o.-i.*t -UK UL.ALI i ; rtCu. 

P.6 

:u^c-4 7oW-= J. 4 

NGA CAAA Implementation Taalc Fftr^e 

HQN Workgroup Recommendrd Discounting Strawy fQr Air Tnxi^ 

Emission Reduction Credits (draft 7/20, 

Discounting Emission Reduction CreHJts 

Discounting Factor 

0% 

10% 

20% 

Applicability 

Eliminate use of HAP 

(Pollution Prevention)10 

Reduction credits 

quantified by 

emission testing01 

Reduction credits 

-quantified by other means'3' 

Rationale. 

Multimedia benefits 

Certain reduction 

in HAP 

Test results generally 

accurate within 10% 

Same discount factor as 

in EPA emissions 

trading policy. 

Greater uncertainty in 

actual reduction, i.e. 

calculation of storage 

tank control emission 

reductions. 

(1) Not including source shutdowns (production reductions). 

(2) Stack tests or continuous emission monitoring. 

(3) Wastewater treatment emissions reductions may not be used for credit because 

of the very high uncertainty (well over 20%) in determining such emissions. 
P.7 

SENT BYAJDEPE •-0 21-9 2 11 48A.M AIR ULALITV REG. 2026247663•* 4/ 4 

B. Tnrer^ive to Overcontrol Short St*rk< 

Incentive 

The effective stack height of air 

toxics sources generating emission 

reduction credits must be less than 

the effective stack height of the 

sources with less than maximum 

achievable control technology 

(MACT) within the MACT 

average. 

Rajiojulfi 

-Overcontrolling lower stacks can cause 

greater air quality benefits than 

overcontrol of higher stacks. 

-Avoiding die control of lower stacks would 

result in net adverse air quality effects. 

-Because of orders of magnitude differences in 

air quality effects, discounting emission 

credits to account for stack height differences 

is not useful. 

-Effective stack height is easily calculated. 

Therefore, this provision is easily applied. 

-Stack height considerations can appropriately 

be addressed in a control technology rule 

(analogous to EPA's Good Engineering 

Practice stack height policy). 
P.8 

RELATIVE IMPACTS FOR EMISSION AVERAGE* 

Emissions =' 1 Ton/Quarter. 

SSASE'. Height = 50' 

Diameter = 2' 

Temperature = 140°F 

Velocity = 25 feet/second 

Emissions = 20001bAnonth / day 

3 mo. /31 days/ 24hr. = °*9 ">'hour. 

55.6 micrograms per cubic meter. 

TANK: Height = 18' 

Diameter = 3' 

Temperature = 90°F 

Velocity = 0.001 feet/second 

Emissions = 20001b 

23.3 mo. =

 85'8 lb/hour. 

Assume: 2 turnovers per quarter. 

10,000 BB1 tank 600 gpm 

2/1Q.QQQ/42 / 

J /600 / 60 =23.3 hours per quarter. 

78,880 micrograms per cubic meter. 

LOADDIG: Height = 10' 

Diameter = 3' 

Temperature = 90°F 

Velocity = 0.001 feet/second 

Emissions = 62.81b fSOOOqal 

1000gal| hour =

 502'4 lb/hour. 

Assume: LL •= 12.46 spm/T 

12.4fi/.6/7.0/6 6 

7 / / 550 = 62.8 hours per 1000 gal. loading. 

500 gal/minute divided by 15 minutes per hour is about 

8000 gallongs loading per hour. 

535,200 micrograms per cubic meter. 

ffASTBNATB: Height a 1' 

Diameter = 3' 

Temperature = 90°F 

Velocity -= 0.001 feet/second 

Emissions a 0.9 pounds per hour 

1017 micrograms per cubic meter with dounwash. 

1.22x10 micrograms per cubic meter without downwash. 

* Estimates generated by Karen Olson, Texas Air Control Board.