P.1 

OAR Box 1672 

Prepped by Charmelle Mathews 

Document Number: 

'JS0JII-C-1O 

Docket Number: 

A-98-13 

Printed 9/30/200811:01:00 AM Sheet 39 of 132 
P.2 

A 98 13 

ll-C-i o 

Date sent: 

From: 

Subject: 

To: 

Copies to: 

Fri, 30 Jan 1998 11:05:35 -0500 

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

Organic Liquids Distribution MACT -Reply 

donna_h@deq.state.la.us 

bhaneke@rtp.pes.com, bnorton@rtp.pes.com, glaflam@rtp.pes 

JHELMS@rtp.pes.com 

Donna, 

We had one major meeting with the industry and are presently moving 

along slowly. Attached is a WordPerfect and PDF file of the handout 

at the industry meeting. We will have a focus meeting with the 

industry in early Febr. to discuss their issues on a draft industry 

ICR survey we plan to send out to collect MACT data. 

How and how much do you want to know and participate in the P-MACT? ] 

will give you a call to discuss! 

The only other State/local contact that Mary Douglas sent me was not 

aware he was picked and did not seem aware MACT. I called and left a 

message for Mary to have this straightened out. 

Thanks for interest! 

Stephen Shedd 

U.S. EPA 

Office of Air Quality Planning and Standards 

Research Triangle Park, NC 27711 

voice: (919) 541-5397 

fax: (919) 541-0246 

E-mail: Shedd.Steve@EPAMAIL.EPA.GOV 

>>> "Hathaway, Donna" <donna_h@deq.state.la.us> 01/29/98 04:30pm >>> 

I contacted Mary Sullivan Douglas on 1/15/97 to inform her that 

Louisiana is interested in participating in this PMACT. She said that 

she gave my name to you. I was wondering if you could provide me with 

an update on this PMACT development. 

Thanks, 

Donna Hathaway 

Louisiana Department of Environmental Quality 

~? ^ \ 

iCs^ 

Bernd Haneke - 1 -- Fri, 30 Jan 1998 12:44:09 
P.3 

1/21/98 

PRESUMPTIVE MACT FOR 

ORGANIC LIQUIDS DISTRIBUTION 

(NON-GASOLINE) FACILITIES 

JANUARY 21,1998 

FIRST ROUNDTABLE MEETING 

WITH PROJECT WORK TEAM 

(PRELIMINARY INFORMATION) 

Waste and Chemical Processes Group 

U.S. Environmental Protection Agency 

Research Triangle Park, NC 

2 
P.4 

OVERVIEW 

Standards Development Process 

Presumptive MACT 

• MACT 

• Project Schedule 

Affected Sources 

• Definition of Source Category 

• Industry Profile 

Model Plants/Facilities 

Emissions and Controls 

• HAP Emissions 

• Control Techniques 

Current Control Levels (MACT Floors) 

Issues/Questions 

Next Steps 

2 

5 
P.5 

STANDARDS DEVELOPMENT 

PROCESS 

3 

H 
P.6 

PRESUMPTIVE MACT IS... 

[MACT = maximum achievable control technology] 

An estimate of what MACT would be, based on a 

review of currently available information 

Assists State and local agencies in making caseby-case MACT determinations 

Not a regulation - offered only for guidance and 

information 

A starting point for the MACT standard 

development process 

4 

6 
P.7 

STATUTORY REQUIREMENTS 

Promulgation of national emission standards 

for hazardous air pollutants (NESHAP) for 

listed source categories required under §112(d) 

of the Clean Air Act 

Organic Liquids Distribution (Non-Gasoline) is 

a listed major source category under §112(c) 

Promulgation of standards is required by 

November 2000 

io 
P.8 

STATUTORY REQUIREMENTS 

(2) 

"Major Source" means any stationary source or 

group of stationary sources located within a 

contiguous area and under common control that 

emits or has the potential to emit, considering 

controls, in the aggregate, 10 tons per year of any 

hazardous air pollutant (HAP) or 25 tons per year 

of any combination of HAP 

"Area Source" means any stationary HAP source 

that is not a major source 

"New Source" means a stationary source, the 

construction or reconstruction of which is 

commenced after the Administrator first proposes 

regulations under §112 establishing an emission 

standard applicable to such source 

"Existing Source" means any stationary source 

other than a new source 

6 
P.9 

STATUTORY REQUIREMENTS 

(3) 

Minimum level of standards ("MACT floor") 

• For existing sources, the standard shall be at 

least as stringent as the average emission 

limitation achieved by the best performing 12 

percent of existing sources, or, in the case of 

categories with less than 30 sources, the 

average emission limitation achieved by the 

best performing 5 sources 

• For new sources, the standard shall be at least 

as stringent as the emission control achieved 

in practice by the best controlled similar 

source 

7 
P.10 

PROJECT SCHEDULE 

(TENTATIVE DATES) 

Event Date 

Kickoff Meetings September 24-25,1997 

Plant Visits Dec. 1997 - Mar. 1998 

Initial Roundtable January 21,1998 

(Work Team) 

Second Roundtable March 20,1998 

(discuss draft P-MACT) 

Third Roundtable May 20,1998 

(review final P-MACT, 

if needed) 

Issue P-MACT Report June 1998 

Start Standards July 1998 

Development Process 

8 
P.11 

AFFECTED SOURCES 

9 

to 
P.12 

HOW IS THE SOURCE CATEGORY 

DEFINED? 

Initial Source Category Description: 

Activities associated with the storage and distribution of 

organic liquids other than gasoline, at sites that serve as 

distribution points from which organic liquids may be 

obtained for further use and processing. For oil and 

gas production, includes only petroleum facilities that 

handle and distribute hydrocarbon liquids after the 

point of custody transferFacility Types May Include: 

• Pipeline facilities 

• Stand-alone terminals 

• Collocated terminals (e.g., associated with refineries or 

chemical plants) 

• Compounding/packaging plants 

10 
P.13 

Organic Liquids Distribution 

Facilities Industry 

CHEMICALS 

Chemical 

Manufacturing 

(SOCMI) 

Consumer 

(Retail) 

i 

Packaging/Distribution 

Facility 

i 

Facilities using 

chemicals as 

feedstocks 

Consumer 

(Retail) 

Packaging/ 

Distribution 

Facility 

PETROLEUM 

Domestic 

Oil/Gas 

Production 

Foreign 

Crude Oil 

Petrochemical 

Manufacturing 

J"1 Petroleum 

Refining 

Consumer 

(Retail) 

Packaging/ 

Distribution 

Facility 

Intermediate Storage and/or Transfer Facility 

11 

\2> 
INDUSTRY PROFILE-BASED ON SIC CODES 

< ^ 

Major 

Group 

4$ 

47 

4* 

Industry 

Group 

Number 

4610 

4780 

4920 

SIC 

Code8 

4612 

4613 

4619 

Q 

4789 

4922 

4923 

4924 

Facility Type" 

PIPELINES 

Pipelines. Except Natural <3as 

Pipelines, Except Natural Gas 

Crude Petroleum Pipelines 

Refined Petroleum Pipelines 

Pipelines, Not Elsewhere Classified 

- - Tfaas|H>rtafion Services . - / 

Miscellaneous Services Incidental to 

Transportation 

Transp. Services, Not Elsewhere Classified 

Gas Production and Distribution 

Natural Gas Transmission and Storage 

Natural Gas Transmbsion and Distribution 

Natural Gas Distribution 

Total No. of 

Establishments11 

1,085 

59 

_• 

2,455 

. 

4,053 

. 

Size Distribution 

by No. of 

Employees1* 

<50 >50 >ibo 

-

95% 

100% 

-

92% 

' 

86% 

- -

3% 

. 

5% 

* 

6% 

2% 

1% 

8% 

12 
4925 Mixed, Manuf., or Liq. Pet Gas Prod./Dist. 

INDUSTRY PROFILE-BASED ON SIC CODES (CONTINUED) 

Major 

Group 

Industry 

Group 

Number 

SIC 

Code8 

Facility Type" Total No. of 

Establishments" 

Size Distribution 

by No. of 

Employeesb 

<50 >50 >100 

STAND-ALONE TERMINALS 

42 

44 

51 

> 

4220 

4490 

5160 

5170 

4226 

4491 

5169 

5171 

5172 

Motor Freight Transportation an<J Warehousing 

Public Warehousing and Storage 

Special Warehousing and Storage, Not Elsewhere 

Classified 

Wa*e*Tratt$ndrtat$oi)y 

Services Incidental to Water Transportation 

Marine Cargo Handling 

Wbok^ale Trade-Nondurable Goods 

Chemicals and Allied Products 

Chemicals and Allied Products, Not Elsewhere 

Classified 

Petroleum and Petroleum Products 

Petroleum Bulk Stations and Terminals 

Petroleum & Petroleum Products Wholesalers, 

except Bulk Stations and Terminals 

1,547 

- -

6,742 

842 

14,722 

10,733 

13,410 

9,241 

3,824 

> f ' * 

93% 

95% 

78% 

97% 

97% 

97% 

97% 

97% 

4% 

2% 

8% 

2% 

2% 

2% 

3% 

2% 

3% 

3% 

14% 

1% 

1% 

1% 

<1% 

1% 

13 
INDUSTRY PROFILE-BASED ON SIC CODES (CONTINUED) 

L* 

Major 

Group 

Industry 

Group 

Number 

SIC 

Code8 

Facility Type" Total No. of 

Establishments11 

Size Distribution 

by No. of 

Employees5 

<50 >50 >100 

COMPOUNDING AND PACKAGING FACILITIES 

19 

47 

2950 

2990 

4780 

•" ' * 

2951 

2992 

' 

4783 

Petroleum ft&fiaing mf&$#te$ f^nslides 

Asphalt Paving and Roofing Materials 

Asphalt Paving Mixtures and Blocks 

Miscellaneous Products of Petroleum and Coal 

Lubricating Oils and Greases 

1

 Traa&portation Services 

Miscellaneous Services Incidental to 

Transportation 

Packing and Crating 

«• _• 

_• , _• s* 

1,324 

1,081 

448 

373 

" " .' 

2455 

90% 

96% 

81% 

83% 

92% 

_• •* s 

6% 

3% 

12% 

10% 

-

5% 

, ' 

4% 

1% 

7% 

7% 

' 

2% 

14 
INDUSTRY PROFILE-BASED ON SIC CODES (CONCLUDED) 

Major 

Group 

Industry 

Group 

Number 

SIC 

Code8 

Facility Type8 Total No. of 

Establishments5 

Size Distribution 

by No. of 

Employees5 

<50 >50 >100 

COLLOCATED DISTRIBUTION FACILITIES (e.g., with chemical or petrochemical facilities) 

9 

• 

9 

• 

9 

• 

9 

• 

9 

• 

9 9 

• 

9 

• 

^ 

"Standard Industrial Classification Manual, 1987 (Office of Management and Budget) 

hCounty Business Patterns, 1995 (Bureau ofthe Census) 

15 
P.18 

HOW IS THE SOURCE CATEGORY 

DEFINED? 

(2) 

Which processes and equipment would be covered? 

• All HAP emission sources at regulated facilities 

• Possible sources: 

- Storage tanks 

- Liquid transfer 

- truck 

- railcar 

- pipeline 

- marine vessel (covered by subpart Y) 

- Equipment leaks 

- Wastewater collection and treatment 

Which liquids? 

Synthetic organic HAP chemicals 

Petrochemicals 

Crude oil or other unrefined petroleum liquids 

Refined petroleum (non-gasoline) 

Other pure liquids or mixtures with HAP content 

16 
P.19 

TOP 20 ORGANIC HAP CHEMICALS 

BY VOLUME (1993-96)1 

Chemical Name 

Ethylene dichloride 

MTBE 

Vinyl chloride 

Methanol 

Styrene 

Ethyl benzene 

Formaldehyde 

Ethylene oxide 

p-Xylene 

Ethylene glycol 

Cumene 

Phenol 

1,3-Butadiene 

Acrylonitrile 

Vinyl Acetate 

Benzene 

Caprolactam 

Aniline 

Methylene chloride 

Phthalic anhydride 

Production (10 metric tons) 

7.2 

6.7 

6.5 

5.1 

5.0 

5.0 

3.7 

3.1 

2.8 

2.5 

2.4 

1.7 

1.6 

1.4 

1.3 

0.9 

0.7 

0.5 

0.5 

0.4 

1 Chemical & Engineering News, 1994-97. 

17 
P.20 

INDUSTRY PROFILE 

(2) 

Model Industry 

• Stand-Alone Organic Liquid Facilities 

(in ILTA Membership) 

Primary SIC codes: 4226, 5169,5171 

• Primary States by Total Storage Capacity: 

State 

Texas 

Louisiana 

New Jersey 

California 

Illinois 

Capacity (barrels) 

55,582,440 

29,383,594 

29,252,303 

24,329,888 

9,881,577 

Range in number of storage tanks: 

1 to 420 + 

Percent of Total 

21% 

11% 

11% 

9% 

4% 

Range in total storage capacity of individual facilities: 

2,700 to 12,500,000 barrels 

Modes of transportation 

- marine vessel (tanker ship, barge) 

- tank truck 

- railcar 

- pipeline 

18 
P.21 

INDUSTRY PROFILE 

(3) 

Collocated Organic Liquid Facilities (e.g., associated 

with refineries or chemical plants) 

SIC codes? 

Pipeline Facilities 

Compounding/Packaging Facilities 

<Data gathering has commenced. All of these facilities 

potentially have four major emission sources: 

• storage 

• transfer operations 

• equipment leaks 

• wastewater> 

19 
P.22 

EMISSIONS AND CONTROLS 

20 

iX 
P.23 

EMISSION FACTORS 

Emissions Calculations 

- HAP content 

- Models/methods for estimating emissions 

- Parameters: volume, loading method, 

vapor pressure, etc.) 

HAP Content 

- pure compound (100% HAP) 

- see chemicals table, page 13 

- always stored at 100% strength? 

- mixtures (partial HAP content) 

- petroleum liquids 

- also diluted pure HAP chemicals? 

- need data (industry survey?) 

Organic Liquids with Partial HAP Content 

Stored 

Liquid 

Crude oil 

Gasoline 

Aviation 

gasoline 

Diesel fuel 

TVP 

(70 °F) 

3-4 

4-8 

9 

• 

? 

Annual Volume 

(Barrels/yr) 

9 

• 

9 

• 

9 

• 

9 

• 

HAP Content in Vapors 

Range 

9 

• 

9 

• 

9 

• 

9 

• 

Average 

9 

• 

9 

• 

9 

• 

9 

• 

21 

2JL 
P.24 

Stored 

Liquid 

Jet 

kerosene 

Other 

petroleum 

mixtures 

Other 

chemical 

mixtures 

Wastewater 

Others? 

TVP 

(70 °F) 

0.01 

9 

• 

9 

• 

9 

• 

9 

• 

Annual Volume 

(Barrels/yr) 

9 

• 

9 

• 

9 

• 

9 

• 

9 

• 

HAP Content in Vapors 

Range 

9 

• 

9 

• 

9 

• 

9 

• 

9 

• 

Average 

9 

• 

9 

• 

9 

• 

9 

• 

9 

• 

Models and Methods 

- Storage tanks 

- AP-42, Section 7.1 (TANKS3 software) 

- Liquid transfer 

- AP-42, Section 5.2 (designed for 

petroleum products) 

- Equipment leaks 

- SOCMI factors 

- refinery factors 

- gasoline marketing facility factors 

- Wastewater air emissions 

- collection and treatment system model (Water 8) 

Facility Parameters (model industry) 

22 

2-3 
P.25 

VAPOR PRESSURES OF SELECTED 

PETROCHEMICALS/PETROLEUM LIQUIDS 

True Vapor Pressure at 70 °F 

Petrochemical/Liquid Vapor Pressure (psia) 

Hydrogen cyanide 11.85 

Ammonium hydroxide (28.8% solution) 10.76 

Diethyl ether 8.70 

Gasoline, RVP 13 8.3 

Methylene chloride 6.79 

Gasoline, RVP 10 6.2 

Gasoline, RVP 7 4.3 

Diethylamine 3.87 

Crude Oil, RVP 5 3.4 

Chloroform 3.19 

Carbon Tetrachloride 1.80 

Jet Naphtha 1.6 

Benzene 1.5 

Acetonitrile 1.4 

Toluene 0.43 

Jet Kerosene 0.011 

#2 Fuel Oil 0.009 

#6 Fuel Oil 0.00006 

23 
P.26 

CONTROL TECHNIQUES 

Storage Tanks 

• Route vapors to control device 

• Floating roof seals and fitting controls 

Liquid Transfer/Loading 

• Vapor balancing 

• Route vapors to control device 

• Vapor-tight vessels (trucks, railcars) 

Equipment Leaks 

• Leak detection and repair program 

• Visual inspections 

Wastewater 

• Cover (eliminate exposure to atmosphere) 

• Treatment 

- oil-water separation 

- biological treatment 

- filtration (sand, carbon, etc.) 

24 
P.27 

CURRENT CONTROL LEVELS 

Information on present levels of control is being 

obtained from: 

• Federal Rules 

Refinery NESHAP (subpart CC) 

Gasoline Distribution NESHAP (subpart R) 

Oil/Natural Gas Production/Transmission 

(subparts HH, HHH) 

Marine Vessel Loading NESHAP (subpart Y) 

Hazardous Organic NESHAP (HON) (subparts 

F, G, H, I) 

Miscellaneous Organic NESHAP (MON) 

Storage Vessel NESHAP (subpart WW) 

Oil-Water Separators (subpart W) 

Benzene Storage and Transfer 

• NSPS rules (Storage Tanks-subpart Kb, etc.) 

25 
P.28 

CURRENT CONTROL LEVELS 

(2) 

Industry Data 

• Plant visits 

• Survey responses 

- screen all facilities? 

- detailed survey: 

• to a limited number of facilities? 

• facility types? 

• types of liquids surveyed? 

• facilities covered by other MACT 

rules? 

• facility size (< 50% of 10/25 tpy HAP 

criteria)? 

- survey packaging and pipeline facilities 

separately? 

• Other information 

26 

1* 
P.29 

CURRENT CONTROL LEVELS 

(3) 

State/Local Rules (Examples) 

• Storage Vessels - California and Illinois rules 

among the most stringent 

tanks > 19,800 gallons, > 1.5 psia, ox 

tanks > 39,630 gallons, > 0.5 psia: 

• floating roof or vapor control at 95% by weight 

any capacity, > 11 psia: 

• pressure tank and vapor control at 95% by weight 

tank cleaning: 

• liquid balancing to < 0.5 psia, or vapor control at 

90% 

• Transfer Operations -Texas, Alaska, and 

California rules among the most stringent 

• > 0.5 psia: vapor control at 90% (Texas) 

• > 1.5 psia: emission limit = 0.08 lb/1,000 gallons 

(lOmg/liter) (Alaska, California) 

• Wastewater Operations - Connecticut, Virginia, 

and Hawaii rules among the most stringent 

• > 200 gallons (VOC>1.5 psia)/day: vapor control 

at 95% (Connecticut, Virginia) 

• > 200 gallons (VOC>0.5 psia)/day: floating roof 

tank (Hawaii) 

27 

2? 
P.30 

ISSUES/QUESTIONS 

What facilities/processes should be included? 

What are the emission sources at compounding 

and packaging operations? 

Impact of the other Federal air rules 

• Do they adequately cover collocated distribution 

emission sources? 

• Which emission sources in presently regulated source 

categories should be considered? 

Impact on or from other media standards 

Water (Benzene Waste NSPS?) 

• Solid waste 

Others? 

28 

0>°\ 
P.31 

ISSUES/QUESTIONS 

(2) 

Area Sources 

• Some are small businesses (how many?) 

• Must cover area sources if they present 

"a threat of adverse effects to human health 

or the environment" (§112(c)(3)) 

• Need to develop simple mechanisms to distinguish 

them from major sources (throughput, equipment 

size, etc.) 

Need additional information to define industry 

and complete industry profile 

Completion of data collection for MACT floor 

determination 

Other questions 

29 

3o 
P.32 

NEXT STEPS 

Finalize and mail out industry survey (ICR) 

Additional site visits 

Develop draft P-MACT 

Second Roundtable Meeting (to receive comments 

on and discuss draft P-MACT) 

Work with Team to gather additional information 

30 

1 \