P.1 

OAR Box 1875 

Prepped by Ollie Stewart 

Document Number: 

52) ll-F-1 

Docket Number: 

A-90-19 

Printed 12/1/200811:12:47 AM Sheet 52 of 86 
P.2 

A-90-19 

ll-F-1 

Attached are materials distributed by the EPA at a meeting 

with OMB on December 18, 1991. Below is a list of attendees. 

EPA 

Michael Shapiro 

Larry Weinstock 

Kathy Kaufman 

Daphne McMurrer 

OMB 

Troy Hillier 

Tim Hunt 

Rick Belzer 

Rob Fairweather 
P.3 

BACKGROUND ON THE HON 

BRIEFING FOR OMB 

December 18, 1991 
P.4 

WHAT DOES THE CLEAN AIR ACT REQUIRE? 

o Emission standards must be based on the maximum degree of emission 

reduction that is achievable considering costs, non-air quality health and 

environmental impacts, and energy requirements (referred to as MACT) 

o May distinguish among classes, types, and sizes within categories and 

subcategories 

o MACT for existing sources cannot be less stringent that the average level 

achieved by the best performing 12% of existing sources in the category 

or subcategory 

o MACT for new sources cannot be less stringent than the level achieved 

in practice by the best performing similar sources 
P.5 

WHAT IS REGULATED BY THE HON? 

o HON regulates the Synthetic Organic Chemical Manufacturing Industry 

(SOCMI) plus 7 non-SOCMI source categories 

o SOCMI has about 660 chemical "Manufacturing Processes" -- roughly 

400 will be subject to this regulation 

o SOCMI facilities usually have several different SOCMI chemical 

manufacturing processes as well as non-SOCMI processes 

o SOCMI facilities have HAP emissions from 5 kinds of emission points: 

Process Vents 

Wastewater Streams 

Transfer Operations 

Storage Tanks 

Equipment Leaks 

o There is a -wide range in sizes and physical characteristics of the 

individual emission points 

o Regulatory Negotiation was used to develop a standard for Equipment 

Leaks — consensus was reached in November 1990 

The other four types of emission points will be covered by the standard 

being developed now 
WHAT ARE THE AFFECTED SOURCE TYPES? 

(D 

STORAGE TANKS 

PROCESS VENTS 0) 

Air oxidation 

nictfiiatinn Organic Emissions 

Wstlllallon htoAlmoshero II 

Reactors Uncontrolled 

m EQUIPMENT 

B

 LEAKS 

WASTEWATER 

TRANSFER 

<5) 

b> 
P.7 

WHY IS THE HON IMPORTANT? 

o Will reduce the volume of HAP emissions more than any other MACT 

standard - by approximately 90,000 to 150,000 tons 

o Will reduce emissions of 149 of the 189 HAPs 

o Will reduce exposure to HAPs 

Sources are concentrated in several geographic areas 

Sources are near residential areas 
P.8 

BASELINE HAP EMISSIONS 

Storage - Large Tanks 2.5% 

Storage - Small Tanks 0.1% 

Storage • Medium Tanks 0.1% 

Transfer 0.1% 

Wastewater 35.7% 

Process Vents 61.5% 

i 
Control Requirements 

HON Existing Sources 

| Emission 

Point 

Process 

Vents 

Wastewater 

Transfer 

Storage 

Small 

Storage 

Medium 

Storage 

Large 

Total 

* denotes floor level 

Emission 

Reduction 

Mg/yr 

236.200 

127,000 

360 

0 

327 

8,600 

372,600 

of control 

% 

for the 

Type 

94 

87 

65 

0 

70 

87 

91.3 

Cost 

$1000/yr 

73,900 

80,400 

3,100 

0 

2,100 

17.100 

176.600 

Avg. 

$/Mg 

313 

635 

8,700 

0 

6,500 

2,000 

475 

Inc. | 

$/Mg. 

3,000 

3.500 

8.700* 

0* 

6.500* 

2.600 

•i 

A 
Control Requirements 

HON New Sources 

Emission 

Point 

Process 

Vents 

Wastewater 

Transfer 

Storage 

Small 

Storage 

Medium 

Storage 

Large 

| Total 

* denotes floor level 

Emisbfon 

Reduction 

Mg/yr 

45.000 

24,200 

70 

60 

60 

1,600 

71,050 

of control 

% 

for the 

Type 

95 

87 

65 

85 

70 

87 

92 

Cost 

$1000/yr 

15,200 

16,600 

600 

1,600 

395 

2.600 

37,000 

Avg. 

$/Mg 

340 

690 

8,700 

24.000 

6.400 

1.600 

620 

Inc. 1 

$/Mg. 1 

340* 

1.600 

8.700* 

24,000* 

6.400* 

730 

| 

o 
P.11 

THE HON REGULATORY PACKAGE 

Subpart F: Applicability and General Requirements 

Subpart G: 

Major Sources 

Specifies regulated pollutants 

Defines SOCMI 

Defines 7 non-SOCMI Equipment Leaks Source Categories 

Provisions for Process Vents, Storage Vessels, Transfer 

Operations, and Wastewater Operations 

o SOCMI only 

o Control requirements 

o Emissions averaging 

Subpart H: Erovis ions for Equipment Leaks 

Regulatory negotiation 

o Work practice standard 
P.12 

SUBPART F 

Specifies covered pollutants 

Organic HAPs 

110 from SOCMI emission points other than Equipment Leaks 

149 from non-SOCMI Equipment Leak Source Categories 

Major Sources 

Defines SOCMI 

400 Chemical Manufacturing Processes 

Process Vents, Storage Vessels, Transfer Operations, Wastewater 

Collection Treatment Operations and Equipment Leaks 

A SOCMI Chemical Manufacturing Process is subject to the HON 

if an organic hazardous air pollutant (HAP) is its: 

o Product, co-product, by-product or intermediate; or 

o Reactant or raw material 

Defines 7 non-SOCMI Equipment Leak Source Categories 

Styrene/butadiene rubber production 

Polybutadiene production 

Chlorine production 

Pesticide production 

Chlorinated hydrocarbon use 

Pharmaceutical production 

Miscellaneous butadiene use 
P.13 

SUBPART G 

o SOCMI Source Category only, excluding equipment leaks 

o Control Requirements 

Reference Control Technology (RCT) 

o Most widely applicable control 

o Similar to control requirements in existing rules 

Applicability Criteria for Control Requirements 

o Determines overall control level from source 

o Compared to the "floor level of control" for each kind of 

emission point 

o Used to define Group 1 and Group 2 points 

o Emissions Averaging 
P.14 

REFERENCE CONTROL TECHNOLOGIES 

o Vents 

TRE approach considering characteristics of stream, including 

concentration and flow rate and costs of combustion 

98% control with flares or incinerators 

o Wastewater 

Control decision based on individual stream characteristics 

95% control by keeping HAPs in stream then using steam stripper 

or other equivalent control 

o Tanks 

Applicability based on capacity and vapor pressure of HAPs in 

tank 

95% control with internal floating roofs or condensers 

o Transfer Operations 

Based on-vapor pressure of HAPs in stream 

98% control using flare or incinerator 
P.15 

THE EMISSIONS AVERAGING APPROACH 

Developed to achieve emission reductions at the lowest possible cost 

Broad range of operations subject to HON 

Some facilities have unusual features 

Cannot tailor the regulation 

Emissions averaging offers flexibility to meet an emission limit in 

the most cost-effective way 

Designed to assure that use of emission averaging will not result 

in an increase in emissions 

Problems with bubbles 

Difficult to enforce 

Requires expensive monitoring and recordkeeping 

Caps total emissions 

Gives sources credits for "normal control" 
P.16 

HOW DOES EMISSIONS AVERAGING WORK? 

o SOCMI is one source category, with no subcategories 

o One regulation for all of SOCMI 

o Each SOCMI facility is a "source" - source includes all emission points 

in SOCMI chemical manufacturing processes subject to the HON and 

in a contiguous area under common control 

o Regulation specifies: 

A series of steps that an owner must use to develop an allowable 

emissions level for each source; and 

The options an owner has for reducing emissions to allowable 

levels 

Allowable emission levels are a function of the plant configuration 

and production rates 

o Regulation allows flexibility while achieving equal or greater emission 

reductions 

Emissions must balance 

o In Mg (tons) 

o On a quarterly basis 
P.17 

L 

HOW DOES EMISSIONS AVERAGING WORK? (CONT) 

Sources may average across: 

o Different kinds of emission points 

o Different chemical manufacturing processes 

o Different pollutants (organic HAPs) 

Credits and Debits based on the efficiency of reference control 

technology 

o Makes emissions averaging different from bubbles 

o Eases enforcement and compliance 

o Regulation divides emission points into 2 Groups 

Group 1 emission points are those points that meet the 

applicability criteria - have control requirements 

Group 2 emission points are those points that do not meet the 

applicability criteria -- have no control requirements 
•a 

EMISSIONS AVERAGING APPROACH (CONT) 

HOW CAN A SOURCE COMPLY WITH ITS EMISSION LIMIT? 

o A source can comply with its emission limit by: 

Controlling Group 1 emissions points with the reference 

technology, or an equivalent technology; or 

Averaging emissions across some of the emission points in the 

facility to meet the emissions limit 

o To get credits to use in emissions averaging a source can: 

Control Group 2 emission points beyond their baseline control 

level 

Control Group 1 emission points with a control that has a 

nominal control efficiency that is higher than the control level of 

the reference technology 

Use pollution prevention to: 

o reduce emissions from Group 1 emission points below the 

level of the reference control technology, or 

o reduce emissions from Group 2 emission points below their 

baseline emissions 

o Credits are equal to the amount of emissions actually reduced 

o Debits equal the amount of emissions that would have been reduced by 

placing the reference control technology on the Group 1 emission point 

that is not being controlled 

o Sources credits and debits must remain in balance over time 
P.19 

/ , 

CREDITS 

Sources of Credits 

1. Overcontrol 

•+-100 tons 

HON reference technology = 98% 

control incinerator 

100 I •+* 2 tons "allowed" 

Source uses "laser destructor" with 

99% efficiency 

100 L.D. lton 

credit = 2 -1 = 1 ton 

•wed actaa! 
P.20 

CREDITS (cont'd) 

Sources of Credits 

2. Pollution Prevention 

-+» 100 tons 

100 I •+» 2 ton "allowed" 

Source uses chemical substitution 

**0 

credit = 2-0 = 2 tons 

allowed actaal 
P.21 

CREDITS (cont'd) 

Sources of Credits 

3. Control source for which control 

technology not required 

•+*2 tons "allowed" 

Source uses incinerator (98%) 

2 _ I "^ .04 tons 

credit = 2 - .04 = 1.96 tons 

allowed actual 

emiarioaa cmaaioos 
P.22 

SUBPART H 

Regulatory Negotiation 

Finished in November 1990 

Representatives from: 

o Petroleum, Chemical, and Pharmaceutical Industries 

o State and local agencies 

r» F.^vVonmental groups 

Agreed to exclude Petroleum Refinery processes 

Work Practice Standard 

Based on pre-existing equipment leak standard 

Cannot be assigned a control efficiency that would be consistent 

across sources or across time for a given source 

Covers 453 chemical manufacturing processes 

Allows staggered implementation 

Includes incentives for good performance