p.1 

OAR Box 1875 

Prepped by Ollie Stewart 

Document Number: 

61) ll-F-8 

Docket Number: 

A-90-19 

Printed 12/1/200811:12:48 AM Sheet 61 of 86 
P.2 

A-90-19 

ll-F-8 

Attached are materials distributed by the EPA at a meeting 

with OMB on August 11, 1992 (p.m.). Below is a list of 

attendees. 

EPA 

Jan Meyer 

Daphne McMurrer 

Bruce Jordan 

Lydia Wegman 

Andrew Otis 

Patricia Embrey 

OMB 

Tim Hunt 

Troy Hillier 

Rick Belzer 

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SPA AIR DOCKET 
P.3 

EPA/OMB Meeting on Technical Changes to the HON 

4 Reasons for Changes 

Corrections 

Clarifications 

Increase Flexibility 

new ideas 

unintentional omissions 

Decrease Burden (without changing reg's effectiveness) 

reevaluation of requirements based on new 

information 

No Individual Change of Great Policy Significance 

However, many small technical changes that should ease 

implementation greatly, especially in combination 

8 Areas of Change 

- Process Vents 

Transfer Operations 

Wastewater 

Storage Vessels 

Emissions Averaging 

Implementation Plan 

Monitoring, Recordkeeping and Reporting 

Applicability 

Most intended changes conceptually complete, being drafted now 

Some changes still being developed/decided upon 

Goal: All changes drafted by September 1 

Possible exceptions: 

Wastewater 

Recordkeeping 

Applicability 
P.4 

o 

o 

o 

o 

Process Vents 

Corrections 

— 

-

TM 

Clar 

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" • 

-

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^ 

Temperature factor on pg. 367 should be 2.494E-06 

TRE "b" constant should be 1.417E-02 

Definition for batch processes 

ifications 

Specify that performance tests are to be conducted under 

representative conditions 

Specify TRE calcs as "TRE Determination Test" or "Group 

Determination Test" to distinguish TRE from performance 

tests 

Specifically exclude low leg drains, high point bleeds, 

analyzer vents and equipment leaks from vents 

requirements 

Clarify requirements for bypass lines 

Specify what is to be monitored for Group 2 vents when no 

recovery device is used 

Specify that HON applies to continuous vents only 

Clarify definition of batch processes 

Increase Flexibility 

— 

TM 

Allow for alternative monitoring for recovery devices 

Considering use of scrubbers as control devices 

Decrease Burden (without changing reg's effectiveness) 

-

-

-

"" 

• -

• 

Remove requirement to calculate TRE for all vent 

combinations 

Remove requirement for TRE calculation for already 

controlled vents 

Add low flow and low concentration cutoffs for TRE calcs 

Allow use of engineering assessments in initial TRE calc 

Require tests and monitoring only if initial 

estimate of TRE value is below 4.0 

Specifically exempt upsets and small unintentional 

process changes from TRE recalc requirements 

Remove requirement for reporting TRE changes unless they 

decrease the TRE below 1.0 or 4.0, whichever is 

applicable 
P.5 

Transfer Operations 

Corrections 

Drop definition of "Marine Vessel" 

Clarifications 

Specify annual throughput used for Group determinations 

Specify how method 27 is to be used 

Specify that the requirements for bypass lines are the 

same as for vents 

Clarify terminology for control devices 

Increase Flexibility 

Allow DOT certification of truck vapor tightness as an 

alternative to method 27 

Allow vapor balancing as both an exemption and a control 

alternative at source's discretion 

Considering use of dome collection devices as a control 

Decrease Burden (without changing reg's effectiveness) 

Remove requirement for loading records at loading site 

Considering necessity of 2 minute temperature monitoring 

requirements for short loading periods 

Exempt boilers using streams as primary fuel from 

performance test requirements (same as vents) 

Allow verification of pressure test certification for 

third party tank trucks and rail cars instead of 

recordkeeping 
P.6 

Wastewater 

Corrections 

Corrected Henry's Law Constants and list of Volatile 

Organic HAP's (VOHAP's) 

Corrected dimensions and mistakes in several equations 

Corrected cross references 

Clarifications 

Specify how sampling can be done at locations other than 

the "Point of Generation" 

Specify which indirect contact streams are exempt 

such as stormwater runoff, safety shower water 

Specify that rule applies primarily to process wastewater 

Specify how bio-units can be used to comply w/HON 

Specify how reports should be handled when there is 

continuous discharge to a POTW 

Reorganized provisions for ease of understanding 

Increase Flexibility 

Considering allowing additional treatment options for 

residuals: 

return to any process 

sale 

Decrease Burden (without changing reg's effectiveness) 

Take comment on alternative leak detection and repair 

program for heat exchange streams 

Considering excluding low volatility VOHAP strippability 

groups 

Considering adding vapor pressure applicability criteria 

for control of wastewater tanks 

Considering addressing landfill leachate in a separate 

standard 

Considering changing de minimis levels from 0.1 ppb and 

0.01 1pm to 5.0 ppm and 0.02 1pm 
P.7 

Storage Vessels 

o Corrections 

Added inspection requirements for internal floating roofs 

that are in service at promulgation or compliance date 

Inadvertently omitted from 12/91 draft 

Corrected applicability criteria to use consistent 

thresholds in preamble and reg 

Added requirement that vessels storing liquids with vapor 

pressure > 76.6 kPa (11.1 psia) must use a closed vent 

system 

Inadvertently omitted from 12/91 draft 

Made all units metric 

Clarifications 

Specify how equipment leaks from closed vent systems on 

storage vessels will be regulated 

Clarify definition of maximum true vapor pressure (for 

the applicability criteria) to include only vapor 

pressures of the HAP's in liquids that are mixtures 

Increase Flexibility 

Allow for delay of repairing closed vent system equipment 

with notification 

Allow an additional 30 day extension for repair of 

floating roofs 

Added a system for delaying inspections when roofs are 

considered structurally unsound (unsafe) 

Specify that working losses are allowed during routine 

maintenance on closed vent systems 

Allow vapor mounted primary seals for external floating 

roofs until tank taken out of service or 10 years after 

promulgation (instead of within after promulgation) 

Decrease Burden (without changing reg's effectiveness) 

Specify that repair of control devices for closed vent 

systems not subject to requirements for routine 

maintenance 

Specify that visual inspection can include use of 

television monitors 
P.8 

Emissions Averaging 

Corrections 

Corrected emissions estimation equations 

Clarifications 

Specified that a 98% closed vent system on a storage 

vessel can generate 3% worth of credits 

Specified that credits from Early Reductions controls can 

only be used after the extension is over and that overcontrolled point is subject to the HON 

Will specify certain pollution prevention measures that 

can be used to generate baseline credits if taken since 

1987 

Clarify that if credits do not exceed debits, all the 

points in the average are not out of compliance 

the balance of credits and debits is an additional 

enforceable commitment, separate from the point-bypoint control commitments for the points in the 

average 

May specify that other standards that include emissions 

averaging will have a different system to determine 

baseline credits 

Need to address precedent that may be interpreted 

as a disincentive for early control 

Increase Flexibility 

Allow credit for increased product recovery on Group 2 

process vents 

Considering how to draft this allowance 

Decrease Burden (without changing reg's effectiveness) 

Considering a compliance system with an annual compliance 

period and quarterly emissions allowances 

Considering allowing baseline credit for 33/50 controls 
-c . 

Implementation Plan 

o Corrections 

Added requirement for a short "initial notification" 

o Clarifications 

Redrafting to make easier to understand 

Adding explanation of the whole reporting system 

o Decrease Burden (without changing reg's effectiveness) 

Applicable only if permit application has not been filed 

Delayed due date to: 

18 months before compliance for points in averages 

12 months before compliance for other points 

Reduced detail needed to describe monitoring plans 

Made some requirements just recordkeeping, not reporting 

Monitoring, Recordkeeping and Reporting 

o Clarifications 

Describing a 5 part reporting system 

Initial notification 

Implementation Plan or Permit Application 

Notification of Compliance Status 

Semi-annual Reports (deviations, performance tests) 

Spot Reports (emissions events, tank inspections) 

Rearranging for clarity and to avoid redundancies 

o Increase Flexibility 

Allow source and delegated authority to develop 

alternative monitoring parameters and parameter ranges 

o Decrease Burden (without changing reg's effectiveness) 

Switch to incentive based semi-annual deviation reporting 

Considering ways to decrease recordkeeping 

Considering ways to decrease reporting of test results 

P.9 
Corrections 

P.10 

Applicability 

Table 2: Chemical names and CAS numbers 

Table 1: HON HAP list matched with corrected list for 

Section 112 

Clarifications 

Describe how source can tell where each chemical 

manufacturing process starts and stops 

Determines which equipment is subject to HON 

Describe how source can tell which chemical manufacturing 

processes are subject to the HON and which are exempt 

Processes are exempt if no HAP's used and no HAP's 

produced 

Clarifying definition of product and by-product 

Clarifying applicability for batch processes 

Specifying that HON does not apply to ethylene units