p.1 

OAR Box 1875 

Prepped by Ollie Stewart 

Document Number: 

4) ll-E-22 

Docket Number: 

A-90-19 

Printed 12/1/200811:12:44 AM Sheet 4 of 86 
P.2 

RADIAN 

A-90-19 

ll-E-22 

MEETING NOTES MEMORANDUM 

X> till " " 2 

TO: Jan Meyer, EPA/SDB 

FROM: Bennett King, Radian 

DATE: March 13, 1991 

ATTENDEES: 

Kathy Bailey, CMA 

Kim Boudeaux, Ethyl 

Ken Ettinger, Chevron 

Leslie Evans, EPA 

Karen Fidler, CMA 

W.C. Holbrook, B.F. Goodrich 

DEC I 8 1992 

I EkXfOk\ • k.C.k.k 

Bennett King, Radian 

Joe Ledvina, Vista 

Jan Meyer, EPA 

Bob Rosensteel, EPA 

Laszlo Takacs, Occidental 

Representatives of the Chemical Manufacturers' Association 

(CMA) and the Environmental Protection Agency's (EPA's) Office of 

Air Quality Planning and Standards (OAQPS) met to discuss the 

Hazardous Organic NESHAP (HON) regulatory development program. 

Discussion covered the points on the attached agenda, although 

did not strictly follow it. The discussion is summarized below 

according to the following major areas: 

Process Vents 

Storage 

Transfer 

Maximum Achievable Control Technology (MACT): New 

versus Existing 

Major and Area Sources 

Processes Subject to the HON 

Sources Already Subject to New Source Performance 

Standards (NSPS) and National Emission Standard 

Hazardous Air Pollutant (NESHAP) Rules 

Agency Information Needs 

Wastewater discussions were deferred to an already scheduled 

meeting for later in the month. 

Process Vents 

The EPA reiterated that current applicability criteria (cutoffs) include flow rate, weight percent concentration, and heat 

content. Total resource effectiveness (TRE) will also need to be 

considered and will be presented to EPA management. The decision 

between these two cut-off types (technical versus straight cost 

effectiveness) is subject to management review. The EPA 

reiterated that some segments of the Agency are sensitive to 

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using TRE because it so heavily emphasizes cost effectiveness. 

Regardless of cut-offs selected, the rules are expected to be 

written similarly to NSPS distillation operations. This approach 

permits the use of alternative control techniques for achieving 

compliance, and does not preclude the use of recovery devices to 

get below applicability cut-offs and avoid the installation of 

controls. The EPA clarified that decisions to develop options, 

concern cut-off levels (which sources need to apply additional 

control), not selections between different control technologies. 

As in previous process vent rules, the control technology 

reduction requirement is likely to be 98 percent total organic 

carbon (TOC) less methane and ethane. The basis of the EPA's 

technical analysis is combustion—a control technology known to 

achieve 98 percent reduction on a wide range of sources. 

The CMA expressed concern about multimedia impacts 

(e.g., solid waste and water pollution impacts) and about the 

production of N0X and CO as a result of combustion. The EPA 

stated that the analysis will quantify N0X and CO emissions and 

will consider multimedia impacts within the limits of our 

knowledge. 

It was discussed that the Process Vents rule may apply vent 

by vent or collectively. The EPA stated that this decision had 

not yet been made. Either approach would use the cut-offs 

described earlier. The CMA expressed a desire for flexibility in 

meeting the 98 percent reduction requirement if a collective vent 

approach was used. 

The EPA clarified that this rule would cover all continuous 

vents—reactor, distillation, and air oxidation. However, EPA 

felt that the broad definition of distillation vents used in the 

NSPS would over most any type of vent found in Synthetic Organic 

Chemical Manufacturing Industry (SOCMI) processes. It would not 

cover batch vents, startup/shutdown operations, or malfunctions. 

The CMA expressed a desire to see draft impacts 

(e.g., control costs and emission reductions) for regulatory 

options. The benefit would be that CMA could point out options 

that would create undue hardship for the SOCMI. The drawback was 

that draft regulatory options are subject to significant change 

and the CMA should not act on them. It was agreed that EPA will 

provide draft impacts for regulatory options, subject to 

management approval, in early summer (late June). It was also 

noted that draft options may not be available until a later date " 

due to ongoing debate on use of risk in MACT decisions and other 

issues. 

Storage 

The EPA reiterated that current applicability criteria 

include storage throughput and vapor pressure. Control 

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technologies are those found in the volatile organic liquids 

(VOL) Storage NSPS. The EPA is unaware of any other universally 

applicable more stringent controls in use for tanks. The CMA 

agreed with that conclusion. Again, decisions on controls will 

be decisions on the size of the source subject to control 

requirements, not selection between different control 

technologies. 

The CMA expressed a concern over de minimis cutoffs for 

applicability of the standards to mixtures of hazardous air 

pollutant (HAP) and non-HAP chemicals. More specifically, trace 

amounts of a HAP can often be found in non-HAP finished products 

(a small amount of benzene is found in linear alkyl benzene). 

The CMA wanted to know whether EPA was considering a minimum HAP 

concentration for mixtures. The EPA responded that this issue 

would be considered. 

Transfer 

The EPA summarized the technical analysis approach used for 

the Transfer project: Section 114 requests were sent to SOCMI 

facilities; based on that information, transfer allocation 

factors were developed for railcars, tank trucks, and marine, 

vessels; model facility transfer racks were developed. According 

to the EPA, the present estimates of transfer emissions are less 

than 200 Mg/yr and controlling them is probably not as cost 

effective as control of other sources. 

The HON will cover tank trucks and railcar transfer, not 

marine vessel transfer. However, marine vessel transfer cost 

impacts will be considered in the economic impacts analysis. 

Marine vessel transfer will be covered under another program, and 

the HON rules will cite that rulemaking. The HON will not cover 

drumming processes. 

The CMA had the same concern with mixtures under the 

transfer project as they did under the storage project. The EPA 

agreed to consider this issue under this project as well. The 

CMA expressed a desire for a concentration cut-off to exclude 

recordkeeping as well as the need to install controls. 

The CMA brought up the issue that connects and disconnects 

of loading pipes were regulated under the vinyl chloride NESHAP 

but not under the benzene NESHAP. They expressed a concern that 

this issue should be addressed in the HON. The EPA agreed to 

consider this in the rulemaking. 

Maximum Achievable Control Technology: New Versus Existing 

The MACT decisions will be made for both new and existing 

sources. Depending on the MACT floors for new and existing 

sources, those decisions may result in the same or different 

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requirements for new and existing sources. The EPA explained the 

basis of the MACT floors for new and existing sources and that 

different floors are what can drive EPA to make different MACT 

decisions for new and existing sources. The MACT floors are 

being developed using existing federal and State regulations as a 

surrogate for actual information on all sources. From this 

regulation review, control technology and applicability criteria 

levels will be selected. The EPA stated that, based on their 

analysis so far, control technologies are the same for new and 

existing sources. 

Major and Area Sources 

The CMA requested clarification as to whether the HON will 

apply to both major and area sources or only major sources. The 

EPA responded that based on their characterization of the SOCMI, 

no area sources are currently included. Further information 

concerning area sources should be collected during the public 

comment period on the Federal Register publication of the Source 

Category List. This information will be used to verify or change 

EPA's current position. 

The EPA stated further that the HON could possibly be 

applied to area sources by showing area sources have an adverse 

health affect. This is still under consideration. Adverse 

health affects can be demonstrated by one of two ways: 

(1) characterization of HAP emissions alone indicate an adverse 

health effect, or (2) perform an analysis to determine adverse 

health affects. 

The EPA also mentioned the lesser quantity cut-offs which 

are set for HAP's. These are typically very small and will 

designate most sources emitting them as major sources. A 

definite approach has not been determined for addressing this 

issue. 

Processes Subject to the HON 

The EPA clarified that the HON will cover the production of 

chemicals marked with a "Y" on the NAPCTAC list of 663 chemicals. 

It was also pointed out that some mistakes exist on the NAPCTAC 

list and it should not be considered final. The EPA has not 

decided the rule will indicate which SOCMI chemicals are subject 

to the HON. 

Sources Already Subject to NSPS and NESHAP Rules 

The CMA expressed their desire that sources already subject 

to NSPS or NESHAP rules not be forced to comply with two sets of 

recordkeeping/reporting requirements and/or control requirements. 

EPA agreed that this was an unnecessary burden and steps would be 

taken to eliminate this situation. 

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SUGGESTED AGENDA FOR 3/13/91 MEETING BETWEEN CMA AND EPA 

I. Review and Discuss CMA Comments on the Hazardous Organic 

NESHAP at January 29-31, 1991 NAPCTAC Meeting 

II. Discuss Issues Related to EPA's Approach for Developing MACT 

Standards for: 

Process Vents 

Transfer Operations 

Storage Tanks 

III. Discuss Applicability Criteria 

IV. Identify Additional Information Needs 

V. Discuss Next Steps 

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Name 

Bennett King 

Laszlo Takacs 

Joe Ledvina 

Leslie Evans 

Jan Meyer 

Bob Rosensteel 

Kim Boudeaux 

W.C. Holbrook 

Karen Fidler 

Ken Ettinger 

Kathy Bailey 

ATTENDEES 

Company 

Radian 

Occidental 

Vista 

EPA 

EPA 

EPA 

Ethyl 

B.F. Goodrich 

CMA 

Chevron Chemical 

CMA 

Telephone Number 

(919 

(716 

(713 

(919 

(919 

(919 

(504 

(216 

(202 

(415 

(202 

) 541-9100 

) 286-3103 

588-3446 

I 541-5410 

541-5254 

| 541-5608 

| 388-7776 

I 447-7925 

| 887-1176 

) 842-5880 

) 887-1186 

MCH/016