P.1 

OAR Box 1672 

Prepped by Charmelle Mathews 

Document Number: 

ll-C-28 

Docket Number: 

A-98-13 

Printed 9/30/2008 11:01:00 AM Sheet 57 of 132 
P.2 

J

0,"% l, 9

i

1 3

. 

S wW* ^ _\ 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY I I - C -2-'? 

I Sw Z ? RESEARCH TRIANGLE PARK. NC 27711 

% PR**-0 

APR 2 9 1998 

OFFICE OF 

AIR QUALITY PLANNING 

James McDerby AND STANDARDS 

Director of Operations 

Weskem-Hall, Inc. 

6300 Bartmer Industrial Drive 

St. Louis, Missouri 63130 i : 

Dear Mr. McDerby: -—;.~ 

The U.S. Environmental Protection Agency (EPA) is compiling detailed information on 

sources and quantities of hazardous air pollutant (HAP) emissions and control techniques. This 

information will be used in setting national emission standards for hazardous air pollutants 

(NESHAP) under section 112 ofthe Clean Air Act (CAA), as amended in 1990. The standards 

will apply to non-gasoline handling operations at both existing and new organic liquids 

distribution facilities. These standards are scheduled to be promulgated by November 2000. The 

EPA's initial steps for this endeavor include the collection of information on HAP emissions and 

emission reduction techniques in the organic liquids distribution industry. Your assistance in 

providing information is critical in developing a regulation that is realistic and workable, as well as 

protective ofthe environment. 

Enclosure 1 itemizes the information that you are requested to submit. The EPA will use 

the information to quantify HAP emissions; define the current status of emission control; and 

assess the environmental, energy, and economic impacts of installing and operating feasible 

emission control techniques. The information needed for regulatory development is contained in 

the information collection form approved by the Office of Management and Budget (OMB No. 

2060-0239). We are sensitive to the amount of labor required to respond to this request; 

therefore, to minimize demands on your time, infonnation specific to the organic liquids 

distribution industry has been extracted from OMB form No. 2060-0239 and formatted to make it 

more relevant to this industry. The EPA consulted industry representatives from both organic 

liquids distribution companies and trade organizations, and their comments improved the 

instructions for this survey as well as its overall focus. Enclosure 1 is the reformatted version of 

the OMB approved form and contains detailed instructions. The OMB approved form is available 

upon request. 

The authority for the EPA's information gathering is included in section 114 ofthe CAA 

(42 U.S.C. 7414). Enclosure 2 contains a summary of this authority. You should also be aware 

that any failure to comply with our request is a violation of section 114 and as such is subject to 

Internet Address (URL) • http://www.epa.gov 

R«cycl»d/Rocyclabl« • Printed with Vegetable Oil Based Inks on Recycled Paper (Minimum 25% Postconsumer) 

la. 
P.3 

enforcement under section 113 (specifically, section 113(d)(1)(B) ofthe CAA, which provides 

civil penalties of up to $25,000 per day of violation). If you believe that disclosure of any 

specific information that you submit would reveal a trade secret, clearly identify such 

information as discussed in the enclosure. Refer to enclosure 2 for the information the EPA may 

require, at a later time, to support your confidentiality claims. Any information determined to 

constitute a trade secret will be protected under 18 U.S.C. 1905. If no claim of confidentiality 

accompanies the information when it is received by the EPA, it may be made available to the 

public by the EPA without further notice (40 CFR part 2.203, September 1,1976). Section 114 

ofthe CAA exempts emission data from claims of confidentiality and emission data collected 

may be made available to the public. A clarification of what the EPA considers to be emission 

data is contained in enclosure 3. 

As noted in enclosure 4, we have designated Pacific Environmental Services, Inc. (PES) 

as an authorized representative ofthe EPA. Therefore, PES has the rights discussed above and in 

enclosure 2. As an authorized representative ofthe EPA, PES is subject to the provisions of 

42 U.S.C. 7414(c) respecting confidentiality of methods or processes entitled to protection as 

trade secrets. The PES contract with the EPA is No. 68D60013. 

Enclosure 5 summarizes Agency and Emission Standards Division policies and 

procedures for handling privileged information and describes EPA contractor commitments and 

procedures for use of confidential materials. It is the EPA's policy that compliance by an 

authorized representative with the requirements detailed in enclosure 5 provides sufficient 

protection for the rights of submitters of privileged information. 

We request that you return the completed information request by July 8,1998. If you 

have any questions regarding this request, please contact Mr. Stephen Shedd of my staff at 

(919) 541-5397, or E-mail address: shedd.steve@epa.gov. 

Sincerely, 

Bruce C.JofdiT 

Director 

Emission Standards Division 

5 Enclosures 

It 
P.4 

ORGANIC LIQUIDS DISTRIBUTION NESHAP 

ORIGINAL MAILING LIST FOR THE 

APRIL 29-MAY 4 1998 MAILOUT 

Ic 
P.5 

Roderick Portine 

Liquid Distribution Manager 

Agway Petroleum Corporation 

Post Office Box 4852 

Syracuse, New York 13221-4852 

Mr. Portine 

Kenneth J. TerBeek 

Manager, Env., Safety, Health and Reg. 

Aldrich Chemical Co., Inc. 

Post Office Box 355 

1001 W. St. Paul Avenue 

Milwaukee, Wisconsin 53233 

Mr. TerBeek 

Rob Adams, Engineering Director 

Allied Energy Corporation 

2700 Ishkooda-Wenonah Road 

Birmingham, Alabama 35211-5705 

Mr. Adams 

Michael E. Law, President 

Allied Terminals, Inc. 

Post Office Box 717 

Norfolk, Virginia 23501 

Mr. Law 

L. Ray Taunton, 

Vice President of Operations 

Allied Signal, Inc. 

101 Columbia Road 

Post Office Box 1057 

Morristown, New Jersey 07962-1057 

Mr. Taunton 

-2^ 
P.6 

Jordan Jacobsen 

Alyeska Pipeline Service Company 

1835 South Bragaw Street 

Anchorage, Alaska 99512 

Mr. Jacobsen 

Robert F. Wright 

President and CEO 

Amerada Hess Corporation 

1185 Avenue ofthe Americas 

New York, New York 10036 

Mr. Wright 

William Schneider, Envir./Safety Mgr. 

American Refining Group, Inc 

2010 William Pitt Way 

Pittsburgh, Pennsylvania 1523 8 

Mr. Schneider 

Stephen Fiverson, President 

American Chemicals Company, Inc. 

49 Central Avenue 

South Kearny, New Jersey 07032 

Mr. Fiverson 

Calvin E. Cain 

American Chemical Corporation 

II Foxe Off. Ctr, #6 Denny Road-#202 

Post Office Box 1168 

Wilmington, Delaware 199899 

Mr. Cain 

3 
P.7 

J.L. McGraw, Director 

Human Resources and Regulatory Affairs 

American Synthetic Rubber 

4500 Campground Road 

Post Office Box 32960 

Louisville, Kentucky 40232 

Mr. McGraw 

Alice Boomhower 

Amoco Chemical Company 

130 East Randolph Drive, P063 

Chicago, Illinois 60601 

Ms. Boomhower 

Greg Skannal 

Amoco Pipeline Company 

One Mid-America Plaza, Suite 300 

Oakbrook Terrace, Illinois 60181 -4723 

Mr. Skannal 

Daniel T. Hisey, Vice President 

Corporate Center Environment, Health and Safety 

Atlantic Richfield Company 

444 South Flower Street 

Los Angeles, California 90071 

Mr. Hisey 

Gregg M. Peckham 

Vice President of Operations 

Archway Sales Inc. 

4155 Manchester Avenue 

St. Louis, Missouri 63110-3823 

Mr. Peckham 

H 
P.8 

Richard Wright 

Ashland Chemical Company 

5200 Blazer Memorial Parkway 

Dublin, Ohio 43017 

Mr. Wright 

Duane D. Gilliam, President 

Ashland Petroleum Company 

Post Office Box 391 

Ashland, Kentucky 41114 

Mr. Gilliam 

Tom Hmiel 

BASF Corporation 

3000 Continental Drive North 

Mt. Olive, New Jersey 07828-1234 

Mr. Hmiel 

L.P. Hughes 

Bayer Corporation 

100 Bayer Road 

Pittsburgh, Pennsylvania 15102 

Mr. Hughes 

Mark A. Gilvin 

Baychem, Inc. 

3200 Moon Station Road 

Kennesaw, Georgia 30144 

Mr. Gilvin 

Aake Gregertsen, President 

Baytank (Houston) Inc. 

12211 Port Road 

Seabrook, Texas 77586 

Mr. Gregertsen 

5 
P.9 

John N. Lauer, President and Chief 

Operating Officer 

BF Goodrich Company 

3925 Embassy Parkway 

Akron, Ohio 44333-1799 

Mr. Lauer 

Kenneth Halligan 

Environmental Compliance Officer 

Borden & Remington Corp. 

106 Ferry Street 

Post Office Box 2573 

Fall River, Massachusetts 02722 

Mr. Halligan 

F.E. Mosier, President 

BP America Inc. 

200 Public Square, 5W 

Cleveland, Ohio 44114-2375 

Mr. Mosier 

Douglas A. Brown 

Brown Chemical Co, Inc. 

302 West Oakland Avenue 

Post Office Box 440 

Oakland, New Jersey 07436-0440 

Mr. Brown 

Patrick Castagna, President 

Carlos R. Leffler, Inc. 

Post Office Box 278 

Richland, Pennsylvania 17078-0278 

Mr. Castagna 

Q 
P.10 

Robert C. Oebser, Group VP 

CENEX 

Post Office Box 64089 

St. Paul, Minnesota 55164-0089 

Mr. Oebser 

Kenneth M. Jaggers 

Vice President, Compliance 

Chemcentral Corporation 

7050 W. 71st Street 

Post Office Box 730 

Bedford Park, Illinois 60499-0730 

Mr. Jaggers 

John K. Swain 

Vice President-Operations 

Chem-Way Corporation 

301 South McDowell 

Suite 706 

Charlotte, North Carolina 28204 

Mr. Swain 

P.M. (Marty) Bitter 

Manager, Federal Relations 

Chevron Corporation 

Post Office Box 7753 

San Francisco, California 94120-7753 

Mr. Bitter 

H. Allen Greene, General Manager 

Environmental and Regulatory Compliance 

CITGO Petroleum Corporation 

Post Office Box 3758 

Tulsa, Oklahoma 74102 

Mr. Greene 

7 
P.11 

Paul Melnuk, President & CEO 

Clark Refining & Marketing, Inc. 

8182 Maryland Avenue 

St. Louis, Missouri 63105 

Mr. Melnuk 

Greg Walthers, Operations Manager 

Coastal Refining & Marketing Co. 

Coastal Tower 9 Greenway Plaza 

Houston, Texas 77046 

Mr. Walthers 

John Robertson 

Coastal Oil New York, Inc. 

Foot of East 5th Street 

Bayonne, New Jersey 07002 

Mr. Robertson 

Don R. Brinkley, President & CEO 

Colonial Pipeline Company 

Post Office Box 18855 

945 East Paces Ferry Road 

Atlanta, Georgia 30326 

Mr. Brinkley 

Robert H. Demere, Jr, President 

Colonial Terminals, Inc. 

North Lathrop Avenue 

Post Office Box 576 

Savannah, Georgia 31402-0576 

Mr. Demere 

f 
P.12 

Stephen Fiverson, President 

Columbia Terminals, Inc. 

Central Avenue 

South Kearny, New Jersey 07032 

Mr. Fiverson 

Pat L. Jernigan 

CONDEA Vista Company 

Vice President, Operations 

Post Office Box 19029 

Houston, Texas 77224-9029 

Mr. Jernigan 

Jeffrey S. Young, Operations Manager 

Continental Industrial Chemicals, Inc. 

5010 Hovis Road 

Charlotte, North Carolina 28208 

Mr. Young 

Richard J. Fitzgerald, Refineries Coordinator 

Conoco Inc. 

Post Office Box 2197 

Houston, Texas 77252 

Mr. Fitzgerald 

Jim Doris, General Manager 

Croda Storage, Inc. 

534 South Front Street 

Elizabeth, New Jersey 07202 

Mr. Doris 

W. L. Warnement, Environmental Safety Affairs Director 

Crown Central Petroleum 

Post Office Box 1759 

Houston, Texas 77251 

Mr. Warnement 

1 
P.13 

Olav S. Urheim, President 

Delaware Terminal Co. 

1050 Christina Avenue 

Wilmington, Delaware 19801 

Mr. Urheim 

Michael Suder, President 

Delta Commodities, Inc. 

3540 River Road 

Post Office Box 581 

Harvey, Louisiana 70059 

Mr. Suder 

Mike Milan, Vice President 

Diamond Shamrock Ref. & Mktg. Co 

100 Northeast Loop 410 

San Antonio, Texas 78216 

Mr. Milan 

Katherine M. Rhodes, Administrative Supervisor 

Dixie Pipeline Company 

1117 Perimeter Center 

Atlanta, Georgia 30338 

Ms. Rhodes 

Maurice Gratton 

Dome Pipeline Corp. 

Amoco Canada Marketing Corp. 

1515 West 22nd Street 

Suite 801 

Oak Brook, Illinois 60521-2007 

Mr. Gratton 

9 

lo 
P.14 

Jackie Alderman 

The Dow Chemical Company 

2030 Willard H. Dow Center 

Midland, Michigan 48674 

Ms. Alderman 

John A. Dege, Manager-Air Programs 

Dupont Environmental Excellence Center 

1007 Market St, N2518-1 

Wilmington, Delaware 19898 

Mr. Dege 

Richard C. Phelps 

Eastman Chemical Company 

Post Office Box 431 

Building 280W 

Kingsport, Tennessee 37662 

Mr. Phelps 

Donald C. Williams 

VP, Environmental and Regulatory Affairs 

Ellis & Everard (US Holdings) Inc. 

700 Galleria Parkway 

Suite 350 

Atlanta, Georgia 30339 

Mr. Williams 

William Allison 

Enron Liquids Pipeline Operating 

Post Office Box 1188 

Houston, Texas 77251-1188 

Mr. Allison 

10 

II 
P.15 

Leslie B. Lampton, President 

Ergon, Inc. 

2829 Lakeland Drive 

Post Office Box 1639 

Jackson, Mississippi 39215-1639 

Mr. Lampton 

Norman L. Morrow 

Exxon Chemical Americas 

13501 Katy Freeway 

Houston, Texas 77079-1398 

Dr. Morrow 

J. Schremp, President 

Firestone Synthetic Rubber & Latex 

381 West Wilbeth Road 

Post Office Box 26611 

Akron, Ohio 44319-0006 

Mr. Schremp 

G. T. Theriot, Manager 

Environmental and Safety Department 

Exxon Company, USA 

Post Office Box 2180 - Room 4291 

Houston, Texas 77252-2180 

Mr. Theriot 

Brett A. Kriley, Environmental Health/Safety Manager 

Fina Oil and Chemical Company 

Post Office Box 2159 

Dallas, Texas 75221 

Mr. Kriley 

11 

/x 
P.16 

Tom O'Donnell, Branch Manager 

Fish-Callahan Chemical Company, Inc. 

18 Industrial Road 

Walpole, Massachusetts 02081 

Mr. O'Donnell 

CA. Bacon, President 

Fleet Supplies, Inc. 

Post Office Box 93831 

Cleveland, Ohio 44101-5831 

Mr. Bacon 

J. F. Chlebowski, President 

GATX Terminals Corporation 

500 West Monroe 

Chicago, Illinois 60661-3678 

Mr. Chlebowski 

John Yates, General Manager 

GE Plastics 

One Plastics Avenue 

Pittsfield, Massachusetts 01201 

Mr. Yates 

Jack A. Bonsky, Vice President and 

General Counsel 

Gencorp Polymer Products 

350 Springside Drive 

Akron, Ohio 44333-2475 

Mr. Bonsky 

12 

13 
P.17 

Thomas G. Swanson, Vice President 

Georgia Gulf Corporation 

400 Perimeter Center Terrace 

Box 105197 

Atlanta, Georgia 30348 

Mr. Swanson 

Robert W. Milk, Exec. Vice President 

The Goodyear Tire and Rubber Co. 

1144 East Market Street 

Akron, Ohio 44316 

Mr. Milk 

Robert M. Gordon, Jr, President 

Gordon Terminal Service Company 

Post Office Box 313 

McKees Rocks, Pennsylvania 15136 

Mr. Gordon 

Vernon Greenlee, President 

Greenville Republic Terminal, Inc. 

Post Office Box 179 

Benoit, Mississippi 38725 

Mr. Greenlee 

Gary R. Kaneb, President 

Gulf Oil, Limited Partnership 

Gulf Oil Building 

90 Everett Avenue 

Chelsea, Massachusetts 02150. 

Mr. Kaneb 

13 

H 
P.18 

George A. Vincent 

President and CEO 

The CP. Hall Company 

311 South Wacker Drive 

Suite 4700 

Chicago, Illinois 60606-6622 

Mr. Vincent 

Monte Naffe, General Manager 

HCI/Advance Chemical Distribution, Inc. 

Post Office Box 70 

Sand Springs, Oklahoma 74063 

Mr. Naffe 

Anne Conley-Pitchell 

Legal Department 

Hoescht-Celanese Chemical Group 

30 Independence Boulevard 

Post Office Box 4415 

Warren, New Jersey 07060-4915 

Ms. Conley-Pitchell 

Jeffrey J. Simko 

Corporate Environmental Manager 

Holland Chemical International (HCl) 

1551 N. Tustin Avenue, Suite 430 

Santa Ana, California 92705-8638 

Mr. Simko 

Bryon K. Fortney, Manager 

Hollywood Marine Inc. 

55 Waugh Drive 

Post Officest Office Box 1343 

Houston, Texas 77251 

Mr. Fortney 

14 

/ * 
P.19 

Joseph A. Lima, Vice President 

Houghton Chemical Corporation 

Post Office Box 307 

52 Cambridge Street 

Allston, Massachusetts 02134 

Mr. Lima 

Willis K. Rossler, Jr, President & CEO 

Houston Fuel Oil Terminal Company 

Post Office Box 969 

Channelview, Texas 77530-0969 

Mr. Rossler 

Jon M. Huntsman, Chairman and CEO 

Huntsman Corporation 

500 Huntsman Way 

Salt Lake City, Utah 84108 

Mr. Huntsman 

Charles Miller Smith, President and CEO 

ICI Americas, Inc. 

3411 Siverside Road 

Wilmington, Delaware 19850 

Mr. Smith 

Joel Fazzio 

International-Matex Tank Terminals 

321 St. Charles Avenue, 3d Floor Suite 

New Orleans, Louisiana 70130 

Mr. Fazzio 

15 

IQ 
P.20 

Herman Luffinan, Chairman, CEO 

Independent Terminal & Pipeline Company 

(ITAPCO) 

530 Wells Fargo Drive, Suite 108 

Houston, Texas 77090 

Mr. Luffinan 

Stephen W. Miles, President 

Intercontinental Terminals Company 

17 Briar Hollow, Suite 402 

Houston, Texas 77027-2896 

Mr. Miles 

John L. MacDonald 

JLM Chemicals, Inc. 

8675 Hidden River Parkway 

Tampa, Florida 33637 

Mr. MacDonald 

Leon E. Hutchens, President 

Kaneb Pipe Line Company 

100 North Broadway, Suite 550 

Wichita, Kansas 67202 

Mr. Hutchens 

J. M. Ehlen 

Koch Refining Company 

Post Office Box 1478 

Houston, Texas 77251-1478 

Mr. Ehlen 

CS. Nobles 

Koch Chemical Company 

Post Office Box 1478 

Houston, Texas 77251-1478 

Mr. Nobles 

16 

n 
P.21 

Glenn Gibisch, President 

Lake River Corporation 

5005 South Harlem Avenue 

Forest View, Illinois 60402 

Mr. Gibisch 

Ronald Espalin, VP of Operations 

Los Angeles Chemical Corporation 

4545 Ardine Street 

Post Office Box 1987 

South Gate, California 90280 

Mr. Espalin 

Dave Cady, President 

Louis Dreyfus Energy Corp. 

Post Office Box 76045 

Atlanta, Georgia 30358-1045 

Mr. Cady 

Kenneth E. Lowe, Jr, Vice President 

Lowe Chemical Company 

8300 Baker Avenue 

Cleveland, Ohio 44102 

Mr. Lowe 

Charles M. Rampacek, President 

Lyondell - CITGO Refining Co. 

Post Office Box 2451 

Houston, Texas 77252-2451 

Mr. Rampacek 

Gary Wilson 

Marathon Oil Company 

539 South Main Street 

Findlay, Ohio 45840 

Mr. Wilson 

17 

S 
P.22 

John Burns, President 

Maritank Inc. 

67th Street at the Schuylkill River 

Philadelphia, Pennsylvania 19153 

Mr. Burns 

R. G. Butler 

Mid-Continent Pipeline Company 

Post Office Box 2039 

Tulsa, Oklahoma 74102-2039 

Mr. Butler 

Motoo Hayashi, Sr. VP 

Mitsubishi International Corporation 

520 Madison Avenue 

18th Floor 

New York, New York 10022 

Mr. Hayashi 

Yuji Takagi, General Manager 

Mitsui & Company 

200 Park Avenue 

New York, New York 10166-0130 

Mr. Takagi 

W. R. Beck 

Mobil Oil Corporation 

3225 Gallows Road 

Fairfax, Virginia 22037-0001 

Mr. Beck 

18 

n 
P.23 

Joseph D. Crowley, President 

New Haven Terminal, Inc. 

100 Waterfront Street 

Post Office Box 9423 

New Haven, Connecticut 06534 

Mr. Crowley 

Donald F. Newman, Chairman 

NOCO Energy Corp. 

700 Grand Island Boulevard 

Post Office Box 86 

Tonawanda, New York 14151 -0086 

Mr. Newman 

Lloyd G. Hansen, President 

Nordix Incorporated of Louisiana 

768 Eventide Drive 

Memphis, Tennessee 38120 

Mr. Hansen 

Nik Mukhopadhyay, Manager 

Occidental Chemical Corporation 

Post Office Box 809050 

Dallas, Texas 75380-9050 

Mr. Mukhopadhyay 

Adrian P. de Monchy, President 

Oiltanking Houston, Inc. 

15602 Jacintoport Boulevard 

Post Office Box 96290 

Houston, Texas 77213-6290 

Mr. de Monfchy 

19 20 
P.24 

Aaron K. Stull, President 

Pacific Coast Chemicals Co. 

2424 4th Street 

Berkeley, California 94710 

Mr. Stull 

Roy E. Wansik, President 

Paktank Corporation 

Suite 2200 

2000 West Loop South 

Houston, Texas 77027-3597 

Mr. Wansik 

Michael L. Rose, Senior Vice President 

Peerless Oil & Chemicals, Inc. 

666 Third Avenue, 30th Floor 

New York, New York 10017 

Mr. Rose 

James J. Keating, President 

Petro-Diamond Terminal Company 

1920 Lugger Way 

Long Beach, California 90813-2634 

Mr. Keating 

Richard C. Nelson, President 

PetroUnited Terminals, Inc. 

Suite 4300 

333 Clay Street 

Houston, Texas 77002 

Mr. Nelson 

20 

1\ 
P.25 

Wayne W. Allen 

Phillips Petroleum Company 

982 Adams Building 

Bartlesville, Oklahoma 74004 

Mr. Allen 

Jon R. Weichbrodt 

Crude Oil Supply Manager 

Phillips 66 Company 

9D 13 Adams Building 

Bartlesville, Oklahoma 74004 

Mr. Weichbrodt 

George Coiner 

Plains Marketing and Transportation Inc. 

1600 Smith Street, Suite 1300 

Houston, Texas 77002 

Mr. Coiner 

Anthony G. Tucker, President 

Powell Duffryn Terminals, Inc. 

Post Office Box 283 

2 Commerce Street 

Bayonne, New Jersey 07002 

Mr. Tucker 

Michael Kooken, Vice President 

PS Trading, Inc. 

5620 Birdcage Street, Suite 130 

Citrus Heights, California 95610 

Mr. Kooken 

21 
P.26 

CA. Lorelli, General Counsel and Secretary 

Reichhold Chemicals, Inc. 

Post Office Box 13582 

Research Triangle Park, North Carolina 27709-3582 

Mr. Lorelli 

Robert E. Lee, President 

River Transportation Company 

5297 River Road 

Post Office Box 33041 

Cincinnati, Ohio 45233 

Mr. Lee 

John P. Mulroney, President 

Rohm and Haas Company 

100 Independence Mall West 

Philadelphia, Pennsylvania 19106-2399 

Mr. Mulroney 

Nat Rowell, President 

Rowell Chemical Corporation 

15 Salt Creek Lane, Suite 205 

Hinsdale, Illinois 60521 

Mr. Rowell 

F.A. Troups, Engineering Manager 

Rubicon, Inc. 

Post Office Box 517 

Geismar, Louisiana 70734 

Mr. Troups 

22 

Z3 
P.27 

Dave Krawczyk 

Solutia, Inc. 

10300 Olive Boulevard (Mail Code F2EP) 

St. Louis, Missouri 63166-6760 

Mr. Krawczyk 

Robert S. English, President 

Solutions 

(Chemical Solutions, Inc.) 

Post Office Box 675 

Franklin, Massachusetts 

Mr. English 

Jordi Baizan, Vice President 

Solvents & Chemicals, Inc. 

Post Office Box 490 

Pearland, Texas 77588 

Mr. Baizan 

Craig A. Overstreet, President 

South Coast Terminals, Inc. 

Post Office Box 15535 

Houston, Texas 77220-5535 

Mr. Overstreet 

Paul T. Owens, President 

Southside River-Rail Terminal, Inc. 

3500 Southside Avenue 

Cincinnati, Ohio 45204 

Mr. Owens 

24 

15 
P.28 

Charles F. Hamilton 

Manager-Regulatory Affairs 

Southwest Solvents & Chemicals 

Post Office Box 41065 

Houston, Texas 77241 

Mr. Hamilton 

Robert J. Nicholson, Jr. 

Operations Manager 

Specialty Chemical Co, Inc. 

Post Office Box 2606 

2018 King Edward Avenue 

Cleveland, Tennessee 37320 

Mr. Nicholson 

Jesse M. Gray 

General Manager 

Star Enterprise/Texaco 

12700 Northborough Drive 

Houston, Texas 77067-2508 

Mr. Gray 

James G. Cameron, President 

Statia Terminals Southwest, Inc. 

c/o Statia Terminals, Inc. 

800 Fairway Drive, Suite 295 

Deerfield Beach, Florida 33441 

Mr. Cameron 

Genarro Dessy, President 

Demaco Corporation 

Post Office Box 8283 

Ponce, Puerto Rico 00732 

Mr. Dessy 

25 

-24 
P.29 

J. Virgil Waggoner, President and CEO 

Sterling Chemicals, Inc. 

1200 Smith Street, Suite 1900 

Houston, Texas 77002-4312 

Mr. Waggoner 

Jacob Bothel Stolt-Nielsen, III 

Stolt-Nielsen Inc. 

15602 Jacintoport Boulevard 

Post Office Box 96438 

Houston, Texas 77213-6438 

Mr. Stolt-Nielsen 

Frank M. Gilbert 

Stratus Petroleum Corporation 

9040 Roswell Road, Suite 380 

Atlanta, Georgia 30350 

Mr. Gilbert 

Newell Baker, Chairman ofthe Board 

Streett, J.D. & Company, Inc. 

144 Weldon Parkway 

Maryland Heights, Missouri 63043 

Mr. Baker 

Patrick E. Coggins, Senior Vice President, 

Environmental and Public Affairs 

Sun Refining & Marketing Co. 

1801 Market Street, 25th Floor 

Philadelphia, Pennsylvania 19103-1699 

Mr. Coggins 

26 
P.30 

Wesley Hickey, President & CEO 

Tidewater Terminal Company 

Six Beach Drive 

Vancouver, Washington 98661-7198 

Mr. Hickey 

H. Roger Holliday, President 

Time Oil Company 

2737 West Commodore Way 

Seattle, Washington 98199 

Mr. Holliday 

Gene C. Gradick, President 

Tonkawa Gas Processing Company 

Fist City Center 

1700 Pacific Avenue 

Dallas, Texas 75201-4696 

Mr. Gradick 

Kevin E. Brown, Air/Regulatory Compliance Mgr. 

Transmontaigne Transp. Services 

Post Office Box 1503 

Fayetteville, Arkansas 72702 

Mr. Brown 

Edward M. Pitkin, President 

Ulrich Chemical, Inc. 

3111 North Post Road 

Indianapolis, Indiana 46226 

Mr. Pitkin 

Newton W. Wilson, President 

Union Texas Petrochemicals 

Post Office Box 2120 

Houston, Texas 77252-2120 

Mr. Wilson 

28 

lJ\ 
P.31 

Sande Wische, President 

W.A.S. Terminals Corporation 

126 Passaic Street 

Newark, New Jersey 07104 

Ms. Wische 

William A. Zartler 

Vice President and General Manager 

Warren Petroleum Company, L.P. 

1000 Louisiana, Suite 5800 

Houston, Texas 77002 

Mr. Zartler 

Arthur Flashinski, Operations Manager 

Wausau Chemical Corporation 

2001 N. River Drive 

Post Office Box 953 

Wausau, Wisconsin 54402-0953 

Mr. Flashinski 

James McDerby 

Director of Operations 

Weskem-Hall, Inc. 

6300 Bartmer Industrial Drive 

St. Louis, Missouri 63130 

Mr. McDerby 

Fred Jones, Vice President 

Westlake Center 

2801 Post Oak Boulevard 

Houston, Texas 77056 

Mr. Jones 

30 

31 
P.32 

Fred Jones, Vice President 

Westlake Petrochemicals Corporation 

Westlake Center 

2801 Post Oak Boulevard 

Houston, Texas 77056 

Mr. Jones 

James R. Lacy, Executive VP 

Westway Terminal Company 

365 Canal Street, Suite 2200 

New Orleans, Louisiana 70130-1134 

Mr. Lacy 

Colie B. Whitaker, Jr, Chairman 

Whitaker Oil Company 

1557 Marietta Road, N.W. 

Atlanta, Georgia 30377 

Mr. Whitaker 

Richard Shore, Vice President 

Wickland Oil Terminals 

90 San Pablo Avenue 

Crockett, California 94525 

Mr. Shore 

Steve Cropper, President and CEO 

Williams Pipe Line Company 

Post Office Box 3448 

Tulsa, Oklahoma 74101 

Mr. Cropper 

Garland Middendorf, Owner 

Wolf Lake Terminals 

Post Office Box 565 

3200 Sheffield 

Hammond, Indiana 46320 

Mr. Middendorf 

31 

3^ 
P.33 

ENCLOSURE 1 

INDUSTRY-SPECIFIC INFORMATION COLLECTION REQUEST 

FOR THE DEVELOPMENT OF AN 

ORGANIC LIQUIDS DISTRIBUTION 

MAXIMUM ACHIEV4ABLE CONTROL TECHNOLOGY (MACT) STAND4ARD 

I. INSTRUCTIONS 

This information request is to be completed for organic liquids distribution (OLD) 

operations at each of your company's plant sites. We are focusing on information regarding 

each organic liquid containing a hazardous air pollutant (HAP) used in or emitted by any 

operation, including fugitive emission and waste sources, that is part ofthe organic liquids 

distribution industry. Attachment A consists ofthe EPA's list of HAP that you should 

refer to when completing the survey. 

Fill out this information request as completely as possible from existing information. At a 

minimum, provide (1) existing information on the presence of HAP emissions and (2) HAP 

emission estimates based on previously obtained test data or on engineering calculations, 

provided there is a basis for such calculations. 

All data and responses should be based on calendar year 1997 emissions, materials 

handled, and emission control equipment (unless you can justify selection of an alternate 

base year). Please be sure to keep a copy ofthe completed survey for your records. You 

should also keep copies of any notes or calculations you perform in completing the survey. 

If you need more space to complete your response, please include the additional 

information in a clearly labeled attachment. If you believe there is additional information 

that is not requested in the survey that may be helpful to the EPA in developing HAP 

emission standards for this industry, please include this information in a separate 

attachment. 

Facilities have two options for completing this survey: 

1. Fill out and return the enclosed paper copy, using copies of blank tables and extra 

sheets as necessary to provide complete answers. The EPA recommends that 

sufficient copies ofthe blank survey be made to accommodate each facility within 

a company that will complete the survey, OR 

2. Locate the electronic version of the survey on the EPA's Technology Transfer 

Network (TTN) [address: http//www.epa.gov/ttn/]. A choice of file types for the 

survey is available. Download the survey and fill it out electronically. Return a 

33 
P.34 

paper copy ofthe completed survey as well as a standard 3.5" diskette containing 

your response. 

Below is information concerning which facilities must complete the survey. 

A. What sfee plaht sites pmst complete the survey? 

This survey is to be completed for any organic liquids distribution (OLD) facilities that are 

large sources of HAP as defined below, or are at plant sites that are large sources of HAP 

as defined below. For the purposes of this survey, the following criteria are to be used to 

determine if an OLD facility is on a plant site that is a large emitter of HAP. The company 

must respond if either: 

1. The plant site has actual annual emissions of 5 tons per year (tpy) or greater of 

any single HAP listed in Attachment A, 0_R 

2. The plant site has actual annual emissions of 12.5 tpy or greater of any 

combination of HAP listed in Attachment A. 

The plant site used for this emissions calculation must include all HAP emission sources 

located within a contiguous area and under common control. Thus, the HAP estimate must 

include all emission sources on the entire plant site, including HAP emissions from both 

distribution and non-distribution operations. (Note: Specific exclusions discussed later in 

this section do not apply here in this HAP emissions calculation.) 

Distribution facilities at plant sites not meeting the large source criteria above. 

Distribution facilities at plant sites with actual HAP emissions below 5 tpy (single HAP) or 

12.5 tpy (combined HAP) do not need to complete this survey and do not need to report 

information on that OLD facility. However, if your company does not have any plant sites 

with OLD facilities meeting the "large source" emissions criteria above, you must report 

this finding in writing to the EPA at the address shown in subsection J of this section. 

B. What types of distribution facilities are covered bv the survey? 

Overall, organic liquids distribution (OLD) facilities that must complete this survey are 

those plant sites having operations that distribute organic liquids that have a HAP content 

and which serve as distribution points from which organic liquids may be obtained for 

further use or processing. Distribution operations include the incoming transfers, storage, 

and outgoing transfer operations, including associated equipment, waste and wastewater 

treatment and disposal practices, and compounding, blending, or packaging activities. 

These distribution activities may be on-site or off-site, or before or after, production plant 

sites such as chemical plants or petroleum refineries. 

31 
P.35_ 

Listed below are exarnples of specific OLD facility types (or combinations thereof), that 

must be included in this survey. These OLD facilities may be separate entities or may be 

contiguous and under common control with a production plant site or each other. 

1. Distribution terminals — these facilities receive, store, and distribute HAPcontaining organic liquids. Liquids normally enter and leave the facility by 

pipeline, marine vessel, tank truck, or railcar, in containers, or by any combination 

of these modes. 

2. Pipeline facilities — these facilities transmit crude oil, natural gas liquids, or other 

organic liquids from or between oil and gas fields, chemical manufacturers, 

petroleum refineries, and distribution facilities. For natural gas liquids and crude 

oil, this survey only covers facilities after the point of custody transfer. 

Additionally, this survey does not cover natural gas facilities. One type of facility 

that is large enough to be covered by this survey occurs along a pipeline and 

contains storage vessels used to relieve surges or receive, gather, and store liquids 

from the pipeline for reinjection and continued transport by the same pipeline or 

to other facilities; these facilities are generally known as pipeline breakout 

stations. Other typical industry names for pipeline facilities that may emit large 

amounts of HAP include, but are not limited to, trunk-line pump stations and 

station storage vessel farms. 

3. Compounding/blending/packaging facilities - these facilities mix HAPcontaining organic liquids together to form a blend or product, and may perform a 

packaging operation by transferring the product into containers of approximately 

600 gallons or smaller. They may constitute a set of operations within a 

distribution terminal or pipeline facility (which may itself be collocated with a 

production plant site), or they could be separate from terminal operations. 

Respondents should recognize that the above described facility types are the most 

prominent examples known to the Agency, but other types may satisfy the "overall" 

description presented earlier in these instructions. 

C. Do all organic liquids need to he surveyed? 

Organic liquids to be surveyed. Provide the requested data only for each organic liquid 

or mixture of liquids that meets both ofthe following criteria: 

1. The organic liquid has a HAP content of 1,000 ppmw or greater, AND 

2. The liquid has an annual average true vapor pressure of 0.1 psia or greater. 

Note that these criteria apply to organic liquids that are transferred into and out ofthe 

36 
P.36 

facility, but do not apply to waste material and wastewater (see below) generated from 

distribution processes and operations. .Also, gasoline is required to be surveyed only under 

the specified conditions presented in subsection G of this section. 

Organic liquid wastes and wastewater to be surveyed. Provide the requested waste or 

wastewater data only for plant sites that generate these waste materials as follows: 

1. All H-AP-containing wastewater streams at plant sites that generate a total of 0.5 

million gallons per year or more of wastewater (excluding segregated stormwater 

runoff). HAP content must be measured prior to exposure to the atmosphere. 

2. All semi-aqueous (10 to 90 percent solids) HAP-containing waste generated from 

distribution equipment or operations. 

Organic liquids and wastes not surveyed. Organic liquids not surveyed because they do 

not meet the criteria in subsection C of this section, but are on site, must be generally 

described and quantified as requested in Section III. Plant Operations, subsection B. 

However, a volume throughput for each ofthe non-surveyed liquids or wastes is not 

required. 

D. What information must be provided for marine vessel loading operations? 

Marine vessel loading operations are subject to Marine Vessel MACT (40 CFR 63, subpart 

Y) and therefore nol the subject of this survey. However, this survey does cover, either 

wholly or partially, some equipment associated with marine vessel loading (i.e., storage 

vessels, shared emission control devices, etc.) as discussed below. 

1. Marine tank vessel terminals that only load or unload product and have no other 

sources of HAP emissions on the plant site, except equipment leaks from the pumps, 

valves, and seals used to load or unload the vessel do not have to complete this survey. If 

the plant site also contains, as an example, a storage vessel containing surveyed organic 

liquids (see earlier subsection C) containing HAP, then these plant sites must submit a 

survey. The required data for those operations are summarized below in subsection D.2. 

2. Marine tank vessel terminal operations at plant sites with other HAP emission 

sources. Provide the following information on marine vessel loading operations: 

a) Show the marine vessel loading operations on the general plot plan in Section III, 

subsection A. 

b) Provide a written description ofthe marine vessel loading operations as requested 

in Section III, subsection B. 

W 
P.37 

c) Fill in the marine vessel loading operation data in wastewater and waste Tables 4, 

5, and 6. 

d) Provide data on each air pollution control device that is not dedicated to (but may 

be shared by) the marine vessel loading operations (Table 9). 

E. What information must be provided for plant sites with chemical manufacturing 

facilities? 

The intent ofthe Organic Liquids Distribution MACT and this section ofthe survey is to 

not overlap the emission sources regulated under the Hazardous Organic NESHAP (HON). 

Only storage vessels, transfer racks, loading arms, and loading hoses that have exclusive or 

predominant use with a regulated chemical manufacturing process unit are required to be 

controlled under the HON (see 40 CFR 63.100(g) and (h)). This survey is collecting 

detailed information as discussed below, on all distribution storage vessels', loading racks, 

loading arms, and loading hoses at the same plant sites with chemical manufacturing 

facilities, unless those emission sources are covered by the HON. 

1. On the plot plan requested in subsection A of Section III, show which storage vessels 

and loading arms and racks are regulated under the HON and which are not. 

"Regulated" vessels, loading arms, and racks include those that are otherwise subject to 

the HON based on association with a process unit, but do not need to be controlled 

because they do not meet the control criteria given in the HON. 

2. For the storage vessels and loading racks for which data are supplied in Tables 2 and 3, 

fill out Table 1 listing the associated surveyed organic liquids, but do not fill out Tables 

4 through 8. 

3. List in Table 2 the presence (but not the requested data) of all distribution storage 

vessels not regulated by the HON because they are part of non-HON regulated process 

units. Also list vessels in tank farms that are contiguous and under common control 

with the plant site and which store and transfer surveyed organic liquids onto or off the 

plant site. Provide the requested Table 2 data for any tank farm or other distribution 

vessels that are nol assigned to a HON-regulated process unit (i.e, an intervening tank 

exists between the vessel and a regulated process unit). 

4. For loading racks, fill out Table 3 (and Table 9 as applicable) for each loading rack, 

arm, or hose that loads surveyed liquids and is not assigned to (does not have exclusive 

'The term "distribution storage vessel" is used to limit this survey to storage tanks used 

for distribution rather than in-process tanks. Generally, distribution tanks are those that store 

organic liquids entering or leaving the plant site. 

3H 
P.38 

or predominant use with) a regulated process unit or is not a tank farm rack subject to 

the HON. 

F. What information must be provided for petroleum refineries? 

The intent ofthe Organic Liquids Distribution MACT and this section ofthe survey is to 

not overlap the emission sources regulated under the Refinery MACT (40 CFR 63, subpart 

CC). Only storage vessels that have exclusive or predominant use with one or more 

regulated process units are regulated by the Refinery MACT (40 CFR 63.640(e)). Also, 

only loading arms handling gasoline are regulated by the Refinery MACT (40 CFR 

63.640(c)(5)). This survey is gathering infonnation as discussed below, on organic liquid 

distribution storage vessels, loading racks, and loading arms no! included in the Refinery 

MACT at the refinery plant site. 

1. On the plot plan requested in subsection A of Section III, show which storage vessels 

are regulated under the Refinery MACT and which are not. "Regulated" vessels include 

those that are otherwise subject to the Refinery MACT, but do not need to be controlled 

because they do not meet the control criteria given in the Refinery MACT. 

2. For the storage vessels and loading racks for which data are supplied in Tables 2 and 3, 

fill out Table 1 listing the associated surveyed organic liquids, but do not fill out Tables 

4 through 8. 

3. List in Table 2 the presence of all distribution storage vessels not regulated by the 

Refinery MACT, such as: 1) those that do not have exclusive or predominant use with a. 

regulated process unit, or 2) those that are in tank farms that are contiguous and under 

common control with the plant site, and which store and transfer surveyed liquids onto 

or off the plant site. 

4. For loading racks, fill out Table 3 (and Table 9 as applicable) for each loading rack and 

arm that loads surveyed liquids other than gasoline into tank trucks or railcars. 

G. What gasoline, gasoline operations, and gasoline facilities need to be surveyed? 

The intent ofthe Organic Liquids Distribution MACT and this section ofthe survey is to 

not overlap the emission sources regulated under the Gasoline Distribution MACT (40 

CFR 63, subpart R) or the applicable portions ofthe Refinery MACT (40 CFR 63, subpart 

CC) noted earlier in this section. Gasoline is the only organic liquid regulated by the 

Gasoline Distribution MACT. However, other products are loaded at those facilities and in 

some cases are organic liquids that are specified not to be surveyed in subsection C of this 

section. Also, if equipment is used in gasoline service but is not dedicated to gasoline 

service, then data are needed on those equipment and operations. Below is a description of 

gasoline operations and facilities that are not to be surveyed or partially surveyed. 

3? 
P.39 

1. Bulk gasoline terminals or pipeline facilities handling onlv gasoline or non-surveved 

liquids. Bulk gasoline terminals and pipeline facilities do not have to submit a response to 

this survey if the facility handles only gasoline and any other organic liquids specified npj 

to be surveyed in subsection C of this section. 

2. Gasoline and gasoline operations at other facilities. All gasoline products (including 

aviation gasoline) must be partially surveyed at all facilities as specified below, unless they 

meet the criteria above in subsection G.l or are not at a plant site that is a large emitter of 

HAP as specified in subsection A of this section. 

a) Gasoline operations must be discussed in Section in. Plant Operations, 

subsection B. 

b) Gasoline information must be provided in the storage, transfer, equipment leak, 

and control equipment sections (Tables 1,2,3,7, and 9) unless, the equipment is: 

(i) in dedicated gasoline service, or 

(ii) regulated under the Gasoline Distribution MACT (40 CFR 63.422,63.423, 

63.424) or the Refinery MACT (40 CFR 63.646,63.648,63.650,63.651). 

However, equipment in dedicated gasoline service or regulated by the Gasoline 

Distribution or Refinery MACT must be shown on the plot plan(s) in Section in . 

Plant Operations, subsection A, and generally described as requested in 

subsection B of Section III. 

c) Gasoline information must be included in wastewater and waste Tables 4,5, and 

6. 

H. Compounding/blending/packaging facilities that have a primary Standard 

Industrial Classification (SIC) code 282.284.285.286.287.289. or 386 are not 

included in this survey and need not be included in the survey response. 

I. If you have questions; 

If you have any questions regarding this request, please contact Mr. Stephen Shedd, U.S. 

EPA, Emission Standards Division, at (919) 541-5397, or e-mail at shedd.steve@epa.gov. 

J. Where to mail responses: 

Return the completed information request and any additional information by the date 

requested in the accompanying letter to: 

31 
Bruce C. Jordan, Director 

Emission Standards Division (MD-13) 

Office of Air Quality Planning and Standards 

U. S. Environmental Protection Agency 

Research Triangle Park, NC 27711 

Attention: Stephen Shedd 

II. GENERAL INFORMATION 

A. Name of legal owner (i.e, parent company) of plant: 

B. Is the company publicly or privately owned? 

C. Name of legal operator of plant, if different from legal owner: 

D. Address of legal owner/operator (please specify which): 

E. Size of company/plant: 

1. Approximate number of employees ofthe business enterprise that owns 

this plant, including where applicable, the parent company and all subsidiaries, 

branches, and unrelated establishments owned by the parent company: . 

2. Total number of employees ofthe business enterprise that operates 

this plant: 

3. a) Number of employees at the entire plant site 

b) Number of employees associated with the organic liquids distribution (nongasoline) operations at this plant: 

c) Number of organic liquids distribution operations employees that are contract 

HO 
P.41 

9 

employees 

F. Name of plant: 

G. Street address of plant: 

City, State, Zip code: _ 

H. Dun and Bradstreet number: 

I. Latitude and longitude coordinates of plant: 

J. Name of contact(s) able to answer technical questions about the completed survey: 

Name 

Title 

Telephone 

Name 

Title ' 

Telephone 

III. PLANT OPERATIONS 

A. Provide a general plot plan ofthe entire plant site within the fenceline, and a more 

detailed figure showing the organic liquid distribution operations. This latter figure should 

clearly indicate all storage vessels and their identifier codes, product loading or transfer 

areas, major product flow lines, wastewater drains and treatment areas, and emission 

control devices. Use the same terminology/codes in identifying facility equipment as you 

will use in completing Tables 1 through 9 in Section IV. For collocated operations, show 

which storage vessels are regulated under an existing MACT and which are not. 

B. Provide a brief written description ofthe distribution facility's operations. List the 

categories (crude oil, gasoline, refined petroleum, solvents, glycols, etc.) of organic liquid 

materials handled during the base year. Also describe all activities that generate HAP 

emissions, including the storage, transfer, handling, and processing (such as blending or 

packaging) ofthe materials, as well as wastewater and other waste handling. Again, please 

use consistent terminology and codes between the plot plan, the written description, and 

Tables 1 through 9 in Section IV. 

C. Include in the written description (Section III, subsection B) the percentage of total 

product shipped from OLD facilities represented by the surveyed liquids (see Section I, 

subsection C for a discussion of surveyed vs. non-surveyed liquids). 

H 
P.42 

10 

D. Provide an estimate for the base year of total HAP emissions from the entire plant site. 

Include the percentage contribution from the organic liquid distribution operations. 

IV. HAP EMISSIONS AND CONTROLS 

Complete Tables 1 through 9, as applicable and subject to the exclusions in Section I, for 

the HAP emission points and control techniques that exist at plant sites containing an 

organic liquids distribution (OLD) facility. Where necessary, make sufficient copies of 

blank tables to provide space for complete responses. Sample entries for these tables can 

be found in Attachment B. Additional guidance to help you fill out these tables is provided 

below: 

1. Table 1-Organic Liquids Stored or Loaded - Enter a name for each HAPcontaining organic liquid stored or loaded at the OLD facility, that meets the 

criteria in subsection C of Section I (i.e, surveyed liquids). This includes both 

pure HAP liquids (e.g, benzene, methanol) and each HAP organic liquid mixture. 

Do not include wastewater in this table (wastewater is to be listed in Tables 4 and 

5). The EPA's complete HAP listing is provided in Attachment A; use either the 

HAP names shown or the corresponding CAS numbers. Where known, include 

(in the table) the requested liquid properties and the identity and concentration of 

HAP present in each liquid. Note: use a separate sheet for each different liquid. 

2. Table 2-Storage Tanks ~ Enter a unique identifier code (e.g, TOI, T02, etc.) for 

each storage tank with greater than 5,000-galloh (« 120-barrel) capacity. Show 

each organic liquid from Table 1 stored in each tank during the base year (and the 

corresponding throughput), using the same liquid codes as used for Table 1. For 

each add-on control device used to control vapor emissions from storage tanks 

(and not dedicated to gasoline operations and/or marine vessel loading), fill out 

Table 9 for that type of device (a separate table for each individual device). 

3. Table 3-Transfer Operations ~ Enter each loading rack/loading arm that 

transfers organic liquids listed in Table 1 to tank trucks, railcars, barges, or tanker 

ships. We are also interested in operations that package these liquids into smaller 

containers, such as 55-gallon drums, 1-gallon or 1-quart cans, etc. (Table 8 

addresses these operations specifically). As in Table 2 for storage tanks, fill out 

Table 9 for each control device used to control vapor emissions from liquid 

transfers, and not dedicated to gasoline operations and/or marine vessel loading. 

4. Table 4-Wastewater Flow and Drain Controls - List the principal sources of 

wastewater generation from distribution activities, using the supplied codes or 

your own code and description. Estimate the annual flow rate from each source, 

and include the HAP constituents and their concentrations in ppmw or mg/l. 

Drains are the individual entry ways to conduits that move water to storage or 

M ^ 
P.43 

11 

treatment. 

5. Table 5-Wastewater Collection and Treatment Control ~ In this table we wish 

to learn how wastewater is collected and treated at the plant site. For each 

wastewater source as listed in Table 4, list the number of collection or treatment 

units applicable to each source. The last four columns request information on 

whether and how air emissions from each area are controlled. As in Tables 2 and 

3, fill out Table 9 for each control device used to control vapor emissions from 

wastewater. 

6. Table 6-Semi-Aqueous Waste ~ Semi-aqueous waste (semi-solid material, or 

sludge) may contain and emit HAP during storage, handling, or treatment. 

Identify each individual type of waste from distribution activities that contains 

any HAP, and provide information on how the waste is collected and treated. As 

in Tables 2,3, and 5, fill out Table 9 for each control device used to control air 

emissions from semi-aqueous waste. 

7. Table 7-Equipment Leaks ~ Leak detection and repair (LDAR) programs 

involve a formal leak survey of equipment components on a fixed schedule (and 

may consist of an instrument or a visual program). As in Tables 2,3, S, and 6, 

fill out Table 9 for each control device used to control vapor emissions from 

equipment components. 

8. Table 8-Compounding/Blending/Packaging Operations ~ This table applies to 

facilities that mix liquids together to form a blend or product, and may package 

the product into smaller, non-mobile containers (approximately 600 gallons down 

to 1 gallon or less). List each separate blend or chemical product made, and the 

surveyed liquids used to form the product (see Section I, subsection C for a 

discussion of surveyed liquids). For families of blended products (i.e, liquids that 

differ only slightly and have the same category name), you may combine these 

products into a single entry in the table. 

9. Table 9-Air Pollution Control Equipment ~ Complete the applicable section of 

Table 9 for each air pollution control device in use at the OLD facility (except 

those dedicated to gasoline service and/or marine tank vessel loadings). Fill in the 

requested parameters if known, showing design, typical, or maximum expected 

values (specify which). Even if you do not know the values, at least identify the 

presence ofthe device by including a table showing the type of device and the 

emission sources that it controls. Please be specific when listing the emission 

sources; e.g. Tanks 1,2, 3, and 7; Loading Racks 1-5 and 11-15; all Oil-Water 

Separators; and so forth. 

f3 
P.44 

12 

TABLE 1. ORGANIC LIQUIDS HANDLED AND HAP CONTENT(a) 

(SURVEYED LIQUIDS) 

I. Organic Liquid Name (b) 

II. Properties (use the same reference temperature for a. and b, and indicate temperature.) 

a. Average True Vapor Pressure (psia): 

b. Density (lb/gal): 

c. Reid Vapor Pressure (psia): 

d. Liquid Molecular Weight (lb/lb-mol @ 70°F): 

e. Vapor Molecular Weight (lb/lb-mol @ 70°F): 

III. HAP Constituents (ofthe organic liquid listed above): 

HAP Constituent (c) CAS No. Average Liquid 

Weight % 

Average Vapor 

Weight % 

(Note: Insert lines as required to list all HAP constituents in the organic liquid. Make sufficient copies 

of this sheet to list all your organic liquids and their HAP constituents.) 

a). Do not list wastewater in this table (for wastewater, refer to Tables 4 and 5). 

b). Provide the complete name for the organic liquid being reported. If the liquid is pure HAP, refer 

to Attachment A and use the name or CAS number shown. For organic liquids referenced in 

Table 8, the family name ofthe liquid may be used in lieu of listing each individual blend. 

c). List all the HAP constituents present in the organic liquid identified in item I. Refer to 

Attachment A for a complete HAP name and CAS No. listing. 

HH 
13 

TABLE 2. STORAGE TANK CONTROL DATA 

UT 

Tank ID Code 

(a) 

Tank Capacity 

(gal) 

(b) 

Name(s) of 

Stored 

Liquid(s) 

(c) 

Annual 

Throughput 

(gal/yr) 

(d) 

Roof 

Configuration 

(e) 

Floating Roof 

Tank Only: 

Seal Type 

(0 

Tank Roof 

Fittings 

(g) 

Add-on 

Control 

Device 

(h) 

Applicable Air 

Regulations 

(0 

See end of table for footnotes. 
P.46 

14 

TABLE 2. STORAGE TANK CONTROL DATA (Continued) 

a). Provide a unique identifier code for each tank (i.e, TOI, T02), matching the codes on the plot 

plan(s). 

b). Provide the maximum or design capacity for each tank. 

c). Names listed must match those shown in Table 1. 

d). Annual throughput should be based upon 1997 values; ifnot, give year and justification. 

e). Select the storage tank roof configuration: 

FXR = fixed roof 

IFR = internal floating roof 

EFR = external floating roof 

CEF - external floating roof converted to an internal floating roof 

P = pressure vessel 

RLT = refrigerated low pressure tank. 

f). For floating roof tanks, enter the floating deck seal type: 

VMl = vapor-mounted primary seal only 

VM2 = vapor-mounted primary seal with weather shield 

VM3 = vapor-mounted primary seal with rim-mounted secondary seal 

LMl = liquid-mounted primary seal only 

LM2 = liquid-mounted primary seal with weather shield 

LM3 = liquid-mounted primary seal with rim-mounted secondary seal 

MSI = mechanical shoe primary seal only 

MS2 = mechanical shoe primary seal with weather shield 

MS3 = mechanical shoe primary seal with rim-mounted secondary seal 

OT = other (please specify type). 

g). For floating roof tanks, select the codes that best describe the types of roof fittings in place: 

GPWUU = guide pole well, unslotted, ungasketed sliding cover 

GPWUG = guide pole well, unslotted, gasketed sliding cover 

GPSWSUN = guide pole/sample well, slotted, ungasketed sliding cover, without float 

GPSWSUF = guide pole/sample well, slotted, ungasketed sliding cover, with float 

GPSWSGN = guide pole/sample well, slotted, gasketed sliding cover, without float 

GPSWSGF = guide pole/sample well, slotted, gasketed sliding cover, with float 

AHBG = access hatch, bolted, gasketed 

AHUU = access hatch, unbolted, ungasketed 

i\HUG = access hatch, unbolted, gasketed 

GFWUU = gauge-float well, unbolted, ungasketed 

GFWUG = gauge-float well, unbolted, gasketed 

GFWBG = gauge-float well, bolted, gasketed 

GHSWG = gauge-hatch/sample well, gasketed 

GHSWU = gauge-hatch/sample well, ungasketed 

VBG = vacuum breaker, gasketed 

% 
P.47 

15 

TABLE 2. STORAGE TANK CONTROL DATA (Concluded) 

VBU = vacuum breaker, ungasketed. 

h). Select the code(s) that best describe control systems, if any, used to control vapors emitted from 

any part ofthe tank, including rim seals, fittings, etc. (provide a unique identifier for each control 

system; e.g, VCS4-1 or VCS4-2). 

VCS 1 = vapor collection system venting to a vapor/liquid absorption unit (scrubber) 

VCS2 = vapor collection system venting to an incinerator/boiler 

VCS3 = vapor collection system venting to a flare 

VCS4 = vapor collection system venting to a vapor/solid adsorption unit 

VCS5 = vapor collection system venting to a condenser 

VCS6 = vapor collection system returning to a process 

VCS7 = vapor collection system returning to a fuel gas system 

B = ground level burner or thermal oxidizer 

C = catalytic oxidizer 

OT = other, please provide a full description (use extra sheet) 

N = none. 

i). Please identify any Federal regulations that apply to each storage tank: 

K = 40 CFR 60 subpart K, Standards of Performance for Storage Vessels for 

Petroleum Liquids for Which Construction, Reconstruction, or Modification 

Commenced After June 11,1973 and Prior to May 19, 1978. 

Ka = 40 CFR 60 subpart Ka, Standards of Performance for Storage Vessels for 

Petroleum Liquids for Which Construction, Reconstruction, or Modification 

Commenced After May 18,1978, and Prior to July 23, 1984. 

Kb = 40 CFR 60 subpart Kb, Standards of Performance for Volatile Organic Liquid 

Storage Vessels (including Petroleum Liquid Storage Vessels) for Which 

Construction, Reconstruction, or Modification Commenced after July 23,1984. 

Y = 40 CFR 61, subpart Y, National Emission Standards for Benzene Emissions 

from Benzene Storage Vessels. 

OT = Other, please identify. 

11 
16 

T4ABLE 3. LIQUID TRANSFER OPERATIONS 

^0 

Organic Liquid 

Transferred 

through Facility 

(a) 

Incoming Type 

of Transport 

Vehicle or 

Container 

(b) 

Loading 

Rack ID 

Code 

(c) 

Loading 

Arm 

ID Code 

(d) 

Outgoing 

Type of 

Transport 

Vehicle or 

Container 

(b) 

Annual Volume of 

Transferred Liquid 

(gal/yr) 

Method of 

Loading or 

Unloading 

(e) 

Average 

Loading or 

Unloading 

Rate 

per Arm 

(gal/min) 

Vapor 

Control 

Device 

(f) 

Control 

Device 

Efficiency 

(g) 

See end of table for footnotes. 
P.49 

17 

TABLE 3. LIQUID TRANSFER OPERATIONS (Concluded) 

a). Organic liquid names must match those listed in Table 1. 

b). Select the type of transport vehicle loaded or unloaded, or container filled: 

TT = tanktruck 

RC = tank car (railroad) 

PL = pipeline 

BG = barge 

TS = tanker ship 

SC = small container (1 gal. or less; specify size) 

MC = medium container (>1 gal., <55 gal.; specify size) 

LC = large container (55 gal. drum or larger; specify size) 

OT = other, please describe. 

c). Provide a unique identifier code for each loading rack or other filling equipment (i.e., LRl, LR2, 

etc.). 

d). Provide a unique identifier code for each loading arm in a rack or equipment unit (i.e., LAI, 

LA2, etc.). 

e). Select the method of loading/unloading organic liquids: 

SPL = splash (top) 

SUB = top submerged 

BTM = bottom loading/fill 

OT = other, please specify. 

f). Use the same control device codes as in footnote "h" of Table 2. 

g). Please provide a control device efficiency estimate. In parentheses, include the basis for this 

estimate as follows: 

SA = sampling and analysis 

EJ = engineering judgment 

ST = source test 

OT = other, please describe. 

It 
18 

TABLE 4. WASTEWATER FLOW RATES AND DRAIN CONTROLS 

O 

Source of OLD 

Wastewater 

(a) 

Total Flow 

Rate 

(gal/yr) 

HAP Name 

(b) 

HAP Concentration 

in Water (ppmw) 

(c) 

Number of Drains 

with Emission 

Suppression 

(d) 

Number of Drains 

without Emission 

Suppression 

(d) 

a). OLD = Organic Liquids Distribution. Select the codes that best describe the points of wastewater generation (insert codes as required and 

provide a full description): 

TC = tank cleanings 

LR = loading racks (identify the specific racks using the same rack codes as in footnote "a" of Table 3. 

LC = line cleanings 

LB = liquid blending/packaging operations 

OT = other, please provide full description (use extra sheet, if necessary). 

b). List the principal HAPs typically present in each wastewater stream. 

c). Estimated annual average concentration during periods of nominal flow in ppmw. 

d). Emission suppression controls reduce emissions from drain pipes and include, but are not limited to, water seal pots and p-traps. 
19 

TABLE 5. WASTEWATER COLLECTION AND TREATMENT CONTROL (a) 

<a\ 

OLD Wastewater 

Treatment Unit 

Total Number of 

Units on Site 

(c) 

No. of Uncovered 

Units that Vent to 

the Atmosphere (d) 

No. of Covered 

Units that Vent to 

the Atmosphere (d) 

No. of Units that 

Vent Emissions to a 

Control Device 

Control Device 

(e) 

Source of Wastewater (b): 

, '%Coflte6tiftnViiits "• ' - • • f'" r -

Manholes 

Junction Boxes 

Sumps/Catch Basins 

Lift Stations 

Storage Tanks 

(0 

*" 4- ^ ' S • " ' 

, Treatment Caife '^ , > t. 

Oil/Water Separators 

Air Flotation Systems 

Coagulation/Precipitation 

Units 

Sand Filtration Unit 

Equalization Units 

See end of table for footnotes. 

bi 
20 

TABLE S. WASTEWATER COLLECTION AND TREATMENT CONTROL (a) (Continued) 

OLD Wastewater 

Treatment Unit 

Total 

Number of 

Units on Site 

(c) 

No. of Uncovered 

Units that Vent to 

the Atmosphere 

(d) 

No. of Covered 

Units that Vent to 

the Atmosphere 

(d) 

No. of Units that 

Vent Emissions to a 

Control Device 

Control Device 

(e) 

Source of Wastewater (b): 

4 ' ' >Ti^iH»nt*Jnlfe ' \ \ '..', ,' '--., '*'".''' S'''-''' , 

Oxidation Ponds 

Activated Sludge Units 

Trickling Filters 

Clarifiers 

Filter Presses 

Strippers 

Effluent/Recycle Pond 

Rotating Biological 

Contactors 

Ship Off Site 

(g) 

See end of table for footnotes. 
P.53 

21 

TABLE 5. WASTEWATER COLLECTION AND TREATMENT CONTROL 

(Concluded) 

a). Include all wastewater collection and treatment units and any control devices controlling vapor 

emissions from such units. Do not report information on drains in this table; report drain 

infonnation in Table 4. 

b). Enter the sources of wastewater within the OLD operations. Use the same codes as in footnote 

"a" of Table 4. 

c). Enter the total number of each type of collection unit and treatment system for each wastewater 

source that is associated with OLD operations. 

d). A unit should be considered covered if it has emission suppression devices in place. 

e). For each collection unit or treatment system vented to a control device, list the device and fill out 

the applicable section of Table 9. Use the same control device codes and format as in footnote 

"h" of Table 2. 

f). Provide the name(s) and other information for any additional wastewater collection unit(s) 

present at the facility. 

g). Provide the name(s) and other information for any additional wastewater treatment unit(s) used 

at the facility. 

53 
22 

TABLE 6. SEMI-AQUEOUS WASTE COLLECTION AND CONTROL (a) 

Type of Waste 

(b) 

Waste Generation 

Rate 

(tons/year) 

(c) 

Waste Collected in 

a Closed System? 

(Yes/No) 

(d) 

Method of On-Site 

Storage 

(e) 

Waste Treated or 

Disposed of OnSite? (Yes/No) 

(0 

Method of On-Site 

Treatment or 

Disposal 

(g) 

Control Device on 

Treatment or 

Disposal Unit 

GO 

See end of table for footnotes. 

2 
23 

TABLE 6. SEMI-AQUEOUS WASTE COLLECTION AND CONTROL (Continued) 

a). Semi-aqueous waste contains any amount of HAP and is between 10 and 90 percent solids. 

b). Select the waste code that best describes the semi-aqueous waste type: 

AP = oil-water separator sludge 

Bl = biotreatment sludge 

HC = contaminated soil 

OD = oily trash and debris 

SO = slop oil emulsions 

SS = sump/sewer clean-out sludge 

B = tank bottoms 

OT = other, please specify (use extra sheet, if necessary). 

c). List the annual semi-aqueous waste generation rate for each type in tons per year (tpy). 

d). Identify (Yes/No) whether the waste is collected in a closed vapor collection system. A closed 

system has equipment to prevent or minimize waste contact with the atmosphere, such as: vapor 

recovery systems, enclosed pipes, or collection units with covers. 

e). Select the storage code that best describes the method by which semi-aqueous waste is stored onsite prior to treatment or disposal: 

AA = open tanks 

BB = fixed roof tanks 

CC = floating roof tanks 

DD = sealed DOT containers (55 gallon drums, 110 gallon bins, etc.) 

EE = open roll-off boxes 

FF = covered roll-off boxes 

GG = open ponds 

HH = covered ponds 

II = open pile 

JJ = covered pile 

OT = other, please specify (use extra sheet, if necessary). 

f). Identify whether waste is treated or disposed of On-Site (Yes) or transported Off-Site (No) for 

treatment and/or disposal. 

g). If waste is treated or disposed of On-Site, select the treatment and/or disposal code(s) that best 

describe(s) how the waste is managed (if more than one code is applicable, separate multiple 

codes with a comma): 

LB = land burial 

LT = land treatment/farming 

DW = dewatering 

ST = solidification/stabilization 

Bl = biotreatment 

IN = incineration/thermal destruction 

RE = recycled 

& 
P.56 

24 

TABLE 6. SEMI-AQUEOUS WASTE COLLECTION AND CONTROL (Concluded) 

OT = other, please specify (use extra sheet, if necessary). 

h). Use the same control device codes as in footnote "h" of Table 2 or describe other devices on a 

separate sheet. 

5C 
P.57 

25 

TABLE 7. EQUIPMENT LEAK CONTROL DATA 

1. Is there a formal, periodic equipment leak detection and repair (LDAR) program? Yes D No D 

Comments: 

2. Please indicate which Federal/State/local rules require an LDAR program at this facility: 

a). 

b)-_ 

c)-_ 

3. If a formal equipment LDAR program has been implemented at your plant, provide the following 

information: 

Definition of a Leak* 

Leak Detection Method1" 

Leak Response Time' 

a). Leak definition codes: 

A = 500 ppmv 

B= 1,000 ppmv 

b). Leak detection codes: 

C= 10,000 ppmv 

D = Bubble formation 

A = EPA Method 21 (vapor detector) 

B = Sight (e.g., drips), smell, sound 

C = Gas detection/alarm system 

E = Sensory detection 

OT = Other (specify) 

D = Soap water application 

E = None 

OT = Other 

c). Provide the maximum allowable time after detection to begin and complete repair of a leak. 

31 
26 

TABLE 7. EQUIPMENT LEAK CONTROL DATA (Concluded) 

Equipment 

Component 

Valves 

Compressors 

Flanges 

Pumps 

Sampling Connections 

Pressure relief valves 

(to atmosphere) 

Inspection 

Frequency 

(a) 

Total 

Equipment 

Count 

Equipment 

Count in 

LDAR 

Program 

Equipment 

Count in 

LDAR with 

HAP Service 

Equipment Counts 

with Mechanical 

Control Devices 

(b) 

Equipment Counts with a 

Closed Vent System 

(c) 

, 

Closed Vent 

System Control 

Device 

(d) 

a). Inspection Frequency Codes: 

M = Monthly 

Q = Quarterly 

T = One time only 

OT = Other (specify) 

A = Annually 

E = After equipment change 

b). 

c). 

d). 

Provide equipment counts for equipment in HAP service with mechanical control devices such as: sealless valves, pumps with dual 

mechanical seals and a barrier fluid, compressors with mechanical seals and a barrier fluid, and pressure relief valves with rupture disks. 

Provide equipment counts for equipment with a vapor collection and recovery (closed vent) system. 

Use the same control device codes and formats as in footnote "h" of Table 2. 
P.59 

27 

TABLE 8. COlVffOUNDING/BLENDING/PACKAGING OPERATIONS 

Parti. 

Product Name 

(a) 

Chemical Composition Annual Quantity 

Produced 

(gal) (c) 

Does a chemical 

reaction take place? 

(d) 

• 

Applicable 

Regulations 

(e) 

a). 

b). 

c). 

d). 

e). 

Provide the product names resulting from blending, compounding, and packaging operations. 

Names must match those provided in Table 1. For families of blends, include only the family 

name listed in Table 1. 

Provide the names ofthe raw materials (must match Table 1) that are used to blend/compound 

the product. 

Provide the annual quantities ofthe products produced. 

Specify whether a chemical reaction takes place during the compounding or blending of organic 

liquids (i.e., yes-compounding, no-blending, etc.). 

Please identify any regulations (pertaining to air emissions) that apply to the 

compounding/blending operation. 

Part II. 

The questions below are facility-wide, and do not need to be answered on a product-by-product basis. 

Please answer the following questions with as much detail as possible. Insert sheets as necessary. 

1. Provide a description ofthe principal methods/mechanisms used for blending/compounding. 

2. Provide a detailed description of any mechanisms of vapor balancing or other vapor emission 

control utilized for these processes (e.g., submerged fill). 

5°i 
P.60 

28 

TABLE 9. AIR POLLUTION CONTROL EQUIPMENT PARAMETERS (a) 

Control Device: Scrubber (b) 

Identifier Code(dV. 

Type of scrubber: 

venturi 

packed bed 

impingement 

other (specify) 

Gas inlet temperature, °F 

Pressure drop, in. H,0 

Liquid-to-gas ratio, gal/103 acfm 

Inlet scrubbing liquor: 

PH 

percent solids 

type of alkali added, if any 

rate (lb/gal) 

Wastewater generation rate, gal/min 

HAP composition of wastewater. mg/I 

Emission Sources (c) 

1. 

2. 

3. 

4. 

5. 

6. 

See end of table for footnotes. 

Co 
P.61 

29 

TABLE 9. AIR POLLUTION CONTROL EQUIPMENT PARAMETERS (a) 

(Continued) 

Control Device: Incinerator (b) 

Identifier Code (d): 

Type: 

thermal 

catalytic 

Combustion chamber temperature, °F 

(please note if temperature measurement is not in chamber) 

Excess air. % 

Nominal residence time, s 

Heat recovery: 

recuperative, percent heat recovery 

regenerative, percent heat recovery 

Emission Sources (c) 

1. 

2. 

3. 

4. 

5. 

6. 

See end of table for footnotes. 

61 
P.62 

30 

TABLE 9. AIR POLLUTION CONTROL EQUIPMENT PARAMETERS (a) 

(Continued) 

Control Device: Flare (b) 

Identifier Code (d): 

Type: 

no assist 

steam assist 

air assist 

pressure assist 

Location: 

ground 

elevated 

Heat content of vented stream. Btu/scf 

Flare gas exit velocity, ft/s 

Flare tip diameter, in. 

Flare height, ft 

Supplementary fuel for: 

pilot, scfm 

combustion purposes, scfm 

Steam requirement lb/hr 

1. 

2. 

3. 

4. 

5. 

6. 

Emission Sources (c) 

See end of table for foomotes. 

(S 
P.63 

31 

TABLE 9. AIR POLLUTION CONTROL EQUIPMENT PARAMETERS (a) 

(Continued) 

Control Device: Carbon Adsorber (b) 

Identifier Code (d): 

Type of carbon bed and number: 

regenerative non-regenerative 

fixed 

fluidized 

How many pounds of carbon per bed 

Configuration: 

parallel 

serial 

Number of beds on-line 

Number of beds desorbing 

Pressure drop. in. H,0 

Gas inlet temperature, °F 

Tvpe of regeneration 

Regeneration time 

Adsorption time 

1. 

2. 

3. 

4. 

5. 

6. 

Emission Sources (c) 

See end of table for footnotes. 

63 
P.64 

32 

TABLE 9. AIR POLLUTION CONTROL EQUIPMENT PARAMETERS (a) 

(Continued) 

Control Device: Condenser (b) 

Identifier Code (d): 

Type of condenser: 

surface 

contact Tif contact see scrubberl 

Gas inlet temperature. °F 

Gas outlet temperature, °F 

1. 

2. 

3. 

4. 

5. 

6. 

Emission Sources (c) 

See next page for foomotes. 

o\ 
P.65 

33 

TABLE 9. AIR POLLUTION CONTROL EQUIPMENT PARAMETERS 

(Concluded) 

a). A separate table should be filled out (after making copies ofthe blank table) for each individual 

scrubber, incinerator, flare, carbon adsorber, or condenser at the facility, unless it is dedicated to 

gasoline service and/or to marine tank vessel loadings. For other types of control devices, 

provide the most important parameters of operation on a separate sheet. 

b). Show ranges, averages, or design values for each parameter and indicate which value is being 

listed. 

c). List specific storage tanks, loading racks/arms, and wastewater and semi-aqueous waste 

treatment or disposal processes, using ID codes and names from Tables 2,3,5, and 6. 

d). For identifier codes, use the same codes as are listed in Table 2, footnote "h". 

tt 
P.66 

34 

ATTACHMENT A - HAZARDOUS Am POLLUTANTS (HAP) 

40 CFR 63.2. HAP means any air poUutant listed in or pursuant to section 112(b) ofthe Act 

CAS No. 

79-34-5 

79-00-5 

57-14-7 

120-82-1 

96-12-8 

122-66-7 

106-88-5 

75-55-8 

106-99-0 

541-75-6 

1120-71-4 

106-46-7 

123-91-1 

540-84-1 

1746-01-6 

95-95-4 

88-06-2 

N/A 

51-28-5 

121-14-2 

95-80-7 

584-84-9 

98-86-2 

532-27-4 

79-46-9 

119-90-4 

119-93-7 

91-94-1 

101-77-9 

101-14-4 

N/A 

92-67-1 

92-93-3 

100-02-7 

75-07-0 

60-35-5 

75058 

98-86-2 

107-02-8 

79-06-1 

79-10-7 

107-13-1 

HAP Name 

1,1,2,2-Tetrachloroethane 

1,1,2-Trichloroethane 

1,1 -Dimethylhydrazine 

1,2,4-Trichlorobenzene 

1,2-Dibromo-3-chloropropane 

1,2-Diphenylhydrazine 

1,2-Epoxybutane 

1,2-Propylenimine (2-Methyl aziridine) 

1,3-Butadiene 

1,3 -Dichloropropene 

1,3-Propane sultone 

1,4-Dicylorobenzene(p) 

1,4-Dioxane (1,4 Diethyleneoxide) 

2,2,4-Trimethylpentane 

2,3,7,8-Tetrachlorodibenzo-p-dioxin 

2,4,5-Trichlorophenol 

2,4,6-Trichlorophenol 

2,4-D, salts and esters 

2,4-Dinitrophenol 

2,4-Dinitrotoluene 

2,4-Toluene diamine 

2,4-Toluene diisocyanate 

2-Acetylaminofluorine 

2-Chloroacetophenone 

2-Nitropropane 

3,3'-Dimethoxybenzidine 

3,3'-Dimethyl benzidine 

3,3'-Dichlorobenzidine 

4,4'-Methylenedianiline 

4,4-Methylene bis (2-chloroaniline) 

4,6-Dinitro-o-cresol and salts 

4-Aminobiphenyl 

4-Nitrobiphenyl 

4-Nitrophenol 

Acetaldehyde 

Acetamide 

Acetonitrile 

Acetophenone 

Acrolein 

Acrylamide 

Acrylic acid 

Acrylonitrile 

cc 
P.67 

35 

ATTACHMENT A - HAZARDOUS AIR POLLUTANTS 

CAS No. 

107-05-1 

62-53-3 

N/A 

N/A 

1332-21-4 

71-43-2 

92-87-5 

98-07-7 

100-44-7 

N/A 

57-57-8 

92-52-4 

111-44-4 

117-81-7 

542-88-1 

75-25-2 

N/A 

156-62-7 

133-06-2 

63-25-2 

75-15-0 

56-23-5 

463-58-1 

120-80-9 

133-90-4 

57-74-9 

7782-50-5 

79-11-8 

108-90-7 

510-15-6 

67-66-3 

107-30-2 

126-99-8 

N/A 

N/A 

N/A 

1319-77-3 

95-48-7 

108-39-4 

106-44-5 

98-82-8 

N/A 

75-55-9 

HAP Name 

Allyl chloride 

Aniline 

Antimony Compounds 

Arsenic Compounds (inorganic including arsine) 

Asbestos 

Benzene 

Benzidine 

Benzotrichloride 

Benzyl chloride 

Beryllium Compounds 

beta-Propiolactone 

Biphenyl 

Dichloroethyl ether 

Bis (2-ethylhexyl) phthalate 

Bis(chloromethyl)ether 

Bromoform 

Cadmium Compounds 

Calcium cyanamide 

Captan 

Carbaryl 

Carbon disulfide 

Carbon tetrachloride 

Carbonyl sulfide 

Catechol 

Chloramben 

Chlordane 

Chlorine 

Chloroacetic acid 

Chlorobenzene 

Chlorobenzilate 

Chloroform 

Chloromethyl methyl ether 

Chloroprene 

Chromium Compounds 

Cobalt Compounds 

Coke Oven Emissions 

Cresols/Cresylic acid 

o-Cresol 

m-Cresol 

p-Cresol 

Cumene 

Cyanide Compounds 

DDE 

(ol 
P.68 

36 

ATTACHMENT A - HAZARDOUS AIR POLLUTANTS 

CAS No. 

334-88-3 

132-64-9 

84-74-2 

111-44-4 

62-73-7 

111-42-2 

64-67-5 

60-11-7 

79-44-7 

68-12-2 

131-11-3 

77-78-1 

106-89-8 

107-21-1 

140-88-5 

100-41-4 

51-79-6 

75-00-3 

106-93-4 

107-06-2 

151-56-4 

75-21-8 

96-45-7 

75-34-3 

N/A 

N/A 

50-00-0 

N/A 

76-44-8 

118-74-1 

87-68-3 

77-47-4 

67-72-1 

822-06-0 

680-31-9 

110-54-3 

302-01-2 

7647-01-0 

7664-39-3 

778-30-64 

123-31-9 

78-59-1 

N/A 

HAP Name 

Diazomethane 

Dibenzofurans 

Dibutylphthalate 

Dichloroethyl ether (Bis(2-chIoroethyl)ether) 

Dichlorvos 

Diethanolamine 

Diethyl sulfate 

Dimethyl aminoazobenzene 

Dimethyl carbamoyl chloride 

Dimethyl formamide 

Dimethyl phthalate 

Dimethyl sulfate 

Epichlorohydrin (l-chloro-2,3-epoxypropane) 

Ethylene glycol 

Ethyl acrylate 

Ethylbenzene 

Ethyl carbamate (Urethane) 

Ethyl chloride (Chloroethane) 

Ethylene dibromide (Dibromoethane) 

Ethylene dichloride (1,2-Dichloroethane) 

Ethylene imine (Aziridine) 

Ethylene oxide 

Ethylene thiourea 

Ethylidene dichloride (1,1 dichloroethane) 

Fine Mineral Fibers 

Mineral fibers 

Formaldehyde 

Glycol ethers 

Heptachlor 

Hexachlorobenzene 

Hexachlorobutadiene 

Hexachlorocyclopentadiene 

Hexachloroethane 

Hexamethylene 1,6-diisocyanate 

Hexamethylphosphoramide 

Hexane 

Hydrazine 

Hydrochloric acid 

Hydrogen fluoride 

Hydrogen sulfide 

Hydroquinone 

Isophorone 

Lead Compounds 

a 
P.69 

37 

ATTACHMENT A - HAZARDOUS AIR POLLUTANTS 

CAS No. HAP Name 

N/A 

108-38-3 

108-31-6 

N/A 

N/A 

67-56-1 

72-43-5 

74-83-9 

74-87-3 

71-55-6 

78-93-3 

60-34-4 

74-88-4 

108-10-1 

624-83-9 

80-62-6 

1634-04-4 

75-09-2 

101-68-8 

121-69-7 

684-93-5 

62-75-9 

59-89-2 

91-20-3 

N/A 

98-95-3 

90-04-0 

95-53-4 

95-47-6 

106-50-3 

106-42-3 

56-38-2 

82-68-8 

87-86-5 

108-95-2 

75-44-5 

7803-51-2 

772-31-40 

N/A 

85-44-9 

1336-36-3 

N/A 

123-38-6 

Lindane (all isomers) 

m-Xylenes 

Maleic anhydride 

Manganese Compounds 

Mercury Compounds 

Methanol 

Methoxychlor 

Methyl bromide 

Methyl chloride 

Methyl chloroform 

Methyl ethyl ketone 

Methyl hydrazine 

Methyl iodide (Iodomethane) 

Methyl isobutyl ketone (Hexone) 

Methyl isocyanate 

Methyl methacrylate 

Methyl tert butyl ether (MTBE) 

Methylene chloride (dichloromethane) 

Methylene diphenyl diisocyanate (MDI) 

N,N-Dimethylaniline 

N-Nitroso-N-methylurea 

N-Nitrosodimethylamine 

N-Nitrosomorpholine 

Naphthalene 

Nickel Compounds 

Nitrobenzene 

o-Anisidine 

o-Toluidine 

o-Xylenes 

p-Phenylenediamine 

p-Xylenes 

Parathion 

Pentachloronitrobenzene (quintobenzene) 

Pentachlorophenol 

Phenol 

Phosgene 

Phosphine 

Phosphorous 

Phosphorus Compounds 

Phthalic anhydride 

Polychlorinated biphenyls (aroclors) 

Polycyclic Organic Matter (POM) 

Propionaldehyde 

(o°l 
P.70 

38 

ATTACHMENT A - HAZARDOUS Am POLLUTANTS (Concluded) 

CAS No. HAP Name 

114-26-1 

78-87-5 

75-56-9 

91-22-5 

106-51-4 

N/A 

N/A 

100-42-5 

96-09-3 

127-18-4 

7550-45-0 

108-88-3 

8001-35-2 

79-01-6 

121-44-8 

1582-09-8 

108-05-4 

593-60-2 

75-01-4 

75-35-4 

1330-20-7 

Propoxur(Baygon) 

Propylene dichloride (1,2 dichloropropane) 

Propylene oxide 

Quinoline 

Quinone 

Radionuclides 

Selenium Compounds 

Styrene 

Styrene oxide 

Tetrachloroethylene (perchloroethylene) 

Titanium tetrachloride 

Toluene 

Toxaphene (chlorinated camphene) 

Trichloroethylene 

Triethylamine 

Trifluralin 

Vinyl acetate 

Vinyl bromide 

Vinyl chloride 

Vinylidene chloride (1,1 dichloroethylene) 

Xylenes (isomeric mixtures) 

70 
P.71 

ATTACHMENT B-EXAMPLE TABLES 

1 
P.72 

ATTACHMENTS 

EXAMPLE TABLE 1. ORGANIC LIQUIDS HANDLED 

AND HAP CONTENT (SURVEYED LIQWDS)(a) 

I. Organic Liquid Name (b) Naphtha 

II. Properties (use the same reference temperature for a. and b., and indicate temperature.) 

a. Average True Vapor Pressure (psia): 3.19 (S>. 72°F 

b. Density (lb/gal): &1 

c. Reid Vapor Pressure (psia): 5.45 

d. Liquid Molecular Weight (lb/lb-mol @70°F): 114.7 

e. Vapor Molecular Weight (lb/lb-mol @ 70°F): ZL2 

III. HAP Constituents (ofthe organic liquid listed above): 

HAP Constituent (c) 

2,2,4 Trimethylpentane 

Benzene 

Cresols 

Cumene 

Ethylbenzene 

CAS No. 

540-84-1 

71-43-2 

1319-77-3 

98-82-8 

100-41-4 

Average Liquid 

Weight % 

0.779 

1.24 

0.019 

0.91 

1.37 

Average Vapor 

Weight % 

2.42 

7.26 

0.0002 

0.252 

0.810 

(Note: Insert lines as required to list all HAP constituents in the organic liquid. Make sufficient copies 

of this sheet to list all your organic liquids and their HAP constituents.) 

a). Do not list wastewater in this table (for wastewater, refer to Tables 4 and 5). 

b). Provide the complete name for the organic liquid being reported. If the liquid is pure HAP, refer 

to Attachment A and use the name or CAS number shown. For organic liquids referenced in 

Table 8, the family name ofthe liquid may be used in lieu of listing each individual blend. 

c). List all the HAP constituents present in the organic liquid identified in item I. Refer to 

Attachment A for a complete HAP name and CAS No. listing. 

1^ 
EXAMPLE TABLE 2. STORAGE TANK CONTROL DATA 

VP 

Tank ID Code 

(a) 

TOI 

T02 

Tank Capacity 

(gal) 

(b) 

40,000 

60,000 

Name(s) of 

Stored 

Liquid(s) 

(c) 

Naphtha 

Aviation Gas 

Annual 

Throughput 

(gal/yr) 

(d) 

60,000,000 

1,000,000 

Roof 

Configuration 

(e) 

EFR 

EFR 

Floating Roof 

Tank Only: 

Seal Type 

(0 

VMl 

VMl 

• 

Tank Roof 

Fittings 

(g) 

GPWUU 

GPWUU 

Add-on 

Control 

Device 

(h) 

N 

N 

Applicable Air 

Regulations 

(0 

Kb 

Kb 

See end of table for foomotes. 

co 
P.74 

EXAMPLE TABLE 2. STORAGE TANK CONTROL DATA (Continued) 

a). Provide a unique identifier code for each tank (i.e., TOI, T02), matching the codes on the plot 

plan(s). 

b). Provide the maximum or design capacity for each tank. 

c). Names listed must match those shown in Table 1. 

d). Annual throughput should be based upon 1997 values; ifnot, give year and justification. 

e). Select the storage tank roof configuration: 

FXR = fixed roof 

IFR = internal floating roof 

EFR = external floating roof 

CEF = external floating roof converted to an internal floating roof 

P = pressure vessel 

RLT = refrigerated low pressure tank. 

f). For floating roof tanks, enter the floating deck seal type: 

VMl = vapor-mounted primary seal only 

VM2 = vapor-mounted primary seal with weather shield 

VM3 = vapor-mounted primary seal with rim-mounted secondary seal 

LMl = . liquid-mounted primary seal only 

LM2 = liquid-mounted primary seal with weather shield 

LM3 = liquid-mounted primary seal with rim-mounted secondary seal 

MSI = mechanical shoe primary seal only 

MS2 = mechanical shoe primary seal with weather shield 

MS3 = mechanical shoe primary seal with rim-mounted secondary seal 

OT = other (please specify type). 

g). For floating roof tanks, select the codes that best describe the types of roof fittings in place: 

GPWUU = guide pole well, unslotted, ungasketed sliding cover 

GPWUG = guide pole well, unslotted, gasketed sliding cover 

GPSWSUN = guide pole/sample well, slotted, ungasketed sliding cover, without float 

GPSWSUF = guide pole/sample well, slotted, ungasketed sliding cover, with float 

GPSWSGN = guide pole/sample well, slotted, gasketed sliding cover, without float 

GPSWSGF = guide pole/sample well, slotted, gasketed sliding cover, with float 

AHBG = access hatch, bolted, gasketed 

AHUU = access hatch, unbolted, ungasketed 

AHUG = access hatch, unbolted, gasketed 

GFWUU = gauge-float well, unbolted, ungasketed 

GFWUG = gauge-float well, unbolted, gasketed 

GFWBG = gauge-float well, bolted, gasketed 

GHSWG = gauge-hatch/sample well, gasketed 

GHSWU = gauge-hatch/sample well, ungasketed 

VBG = vacuum breaker, gasketed 

IH 
P.75 

EXAMPLE TABLE 2. STORAGE TANK CONTROL DATA (Concluded) 

VBU = vacuum breaker, ungasketed. 

h). Select the code(s) that best describe control systems, if any, used to control vapors emitted from 

any part ofthe tank, including rim seals, fittings, etc. (provide a unique identifier for each control 

system; e.g., VCS4-1 or VCS4-2). 

VCS 1 = vapor collection system venting to a vapor/liquid absorption unit (scrubber) 

VCS2 = vapor collection system venting to an incinerator/boiler 

VCS3 = vapor collection system venting to a flare 

VCS4 = vapor collection system venting to a vapor/solid adsorption unit 

VCS5 = vapor collection system venting to a condenser 

VCS6 = vapor collection system returning to a process 

VCS7 = vapor collection system returning to a fuel gas system 

B = ground level burner or thermal oxidizer 

C = catalytic oxidizer 

OT = other, please provide a full description (use extra sheet) 

N = none. 

i). Please identify any Federal regulations that apply to each storage tank: 

K = 40 CFR 60 subpart K, Standards of Performance for Storage Vessels for 

Petroleum Liquids for Which Construction , Reconstruction, or Modification 

Commenced After June 11,1973 and Prior to May 19,1978. 

Ka = 40 CFR 60 subpart Ka, Standards of Performance for Storage Vessels for 

Petroleum Liquids for Which Construction, Reconstruction, or Modification 

Commenced After May 18,1978, and Prior to July 23,1984. 

Kb = 40 CFR 60 subpart Kb, Standards of Performance for Volatile Organic Liquid 

Storage Vessels (including Petroleum Liquid Storage Vessels) for Which 

Construction, Reconstruction, or Modification Commenced after July 23,1984. 

Y = 40 CFR 61, subpart Y, National Emission Standards for Benzene Emissions 

from Benzene Storage Vessels. 

OT = Other, please identify. 

15 

 
EXAMPLE TABLE 3. LIQUID TRANSFER OPERATIONS 

- 3 

Organic Liquid 

Transferred 

through Facility 

(a) 

Naphtha 

Naphtha 

Aviation Gas 

Incoming Type 

of Transport 

Vehicle or 

Container 

0>) 

BG 

BG 

PL 

Loading 

Rack ID 

Code 

(c) 

LRl 

LR2 

LR3 

Loading 

Arm 

ID Code 

(d) 

LRl, Al-4 

LR2, Al-4 

LR3, A2-4 

Outgoing 

Type of 

Transport 

Vehicle or 

Container 

(b) 

TT 

RC 

TT 

Annual Volume of 

Transferred Liquid 

(gal/yr) 

1,000,000 

59,000,000 

1,000,000 

Method of 

Loading or 

Unloading 

(e) 

BTM 

BTM 

BTM 

Average 

Loading or 

Unloading 

Rate 

per Arm 

(gal/min) 

500 

1,000 

500 

Vapor 

Control 

Device 

(0 

VCS4-1 

VCS4-1 

VCS2 

Control 

Device 

Efficiency 

(g) 

95% 

95% 

98% 

See end of table for foomotes. 
P.77 

EX4AMPLE TABLE 3. LIQUID TRANSFER OPERATIONS (Concluded) 

a). Organic liquid names must match those listed in Table 1. 

b). Select the type of transport vehicle loaded or unloaded, or container filled: 

TT = tanktruck 

RC = tank car (railroad) 

PL = pipeline 

BG = barge 

TS = tanker ship 

SC = small container (1 gal. or less; specify size) 

MC = medium container (>1 gal., <55 gal.; specify size) 

LC = large container (55 gal. drum or larger; specify size) 

OT = other, please describe. 

c). Provide a unique identifier code for each loading rack or other filling equipment (i.e., LRl, LR2, 

etc.). 

d). Provide a unique identifier code for each loading arm in a rack or equipment unit (i.e., LAI, 

LA2, etc.). 

e). Select the method of loading/unloading organic liquids: 

SPL = splash (top) 

SUB = top submerged 

BTM = bottom loading/fill 

OT = other, please specify. 

f). Use the same control device codes as in footnote "h" of Table 2. 

g). Please provide a control device efficiency estimate. In parentheses, include the basis for this 

estimate as follows: 

SA = sampling and analysis 

EJ = engineering judgment 

ST = source test 

OT = other, please describe. 

11 
EXAMPLE TABLE 4. WASTEWATER FLOW RATES AND DRAIN CONTROLS 

^ 

Source of OLD 

Wastewater 

(a) 

Tank Cleanings (TC) 

Line Cleanings (LC) 

Total Flow 

Rate 

(gal/yr) 

500,000 

100,000 

HAP Name 

(b) 

Benzene 

1,2 Dichloroethane 

Methylene chloride 

Phenol 

Benzene 

Methanol 

Xylene 

HAP Concentration 

in Water (ppmw) 

(c) 

500 

10 

300 

1,000 

200 

1,000 

560 

Number of Drains 

with Emission 

Suppression 

(d) 

5 

4 

Number of Drains 

without Emission 

Suppression 

(d) 

0 

0 

a). OLD = Organic Liquids Distribution. Select the codes that best describe the points of wastewater generation (insert codes as required and 

provide a full description): 

TC = tank cleanings 

LR = loading racks (identify the specific racks using the same rack codes as in footnote "a" of Table 3. 

LC = line cleanings 

LB = liquid blending/packaging operations 

OT = other, please provide full description (use extra sheet, if necessary). 

b). List the principal HAPs typically present in each wastewater stream. 

c). Estimated annual average concentration during periods of nominal flow in ppmw. 

d). Emission suppression controls reduce emissions from drain pipes and include, but are not limited to, water seal pots and p-traps. 

oo 
8 

EXAMPLE TABLE 5. WASTEWATER COLLECTION AND TREATMENT CONTROL (a) 

OLD Wastewater 

Treatment Unit 

Total Number of 

Units on Site 

(c) 

No. of Uncovered 

Units that Vent to 

the Atmosphere (d) 

No. of Covered 

Units that Vent to 

the Atmosphere (d) 

No. of Units that 

Vent Emissions to a 

Control Device 

Control Device 

(e) 

Source of Wastewater (b): Tank Cleanings 

; — ' 'C^teetSoBt/nite ,- - , " ,, „-'-y ,«',. '/' S, '',-•*'' " 

Manholes 

Junction Boxes 

Sumps/Catch Basins 

Lift Stations 

Storage Tanks 

(0 

20 

3 

1 

0 

1 

0 

0 

0 

0 

20 

3 

1 

0 

0 

0 

0 

0 

1 

0 

0 

0 

0 

VCS4-2 

,-4 Treatment Unit? -'„ , ' , '-,-. ' 

Oil/Water Separators 

Air Flotation Systems 

Coagulation/Precipitation 

Units 

Sand Filtration Unit 

Equalization Units 

3 

n/a 

n/a 

n/a 

n/a 

3 

See end of table for foomotes. 
EXAMPLE TABLE 5. WASTEWATER COLLECTION AND TREATMENT CONTROL (a) (Continued) 

o 

OLD Wastewater 

Treatment Unit 

Total 

Number of 

Units on Site 

(c) 

No. of Uncovered 

Units that Vent to 

the Atmosphere 

(d) 

No. of Covered 

Units that Vent to 

the Atmosphere 

(d) 

No. of Units that 

Vent Emissions to a 

Control Device 

Control Device 

(e) 

Source of Wastewater (b): Tank Cleanings 

Tr*ajm«ku»it!»4 ' ' ' / , "/- ," - " -, " ' 

Oxidation Ponds 

Activated Sludge Units 

Trickling Filters 

Clarifiers 

Filter Presses 

Strippers 

Effluent/Recycle Pond 

Rotating Biological 

Contactors 

Ship Off Site 

(g) 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

n/a 

See end of table for foomotes. 
P.81 

10 

EXAMPLE TABLE 5. WASTEWATER COLLECTION AND TREATMENT 

CONTROL (Concluded) 

a). Include all wastewater collection and treatment units and any control devices controlling vapor 

emissions from such units. Do not report information on drains in this table; report drain 

information in Table 4. 

b). Enter the sources of wastewater within the OLD operations. Use the same codes as in footnote 

"a" of Table 4. 

c). Enter the total number of each type of collection unit and treatment system for each wastewater 

source that is associated with OLD operations. 

d). A unit should be considered covered if it has emission suppression devices in place. 

e). For each collection unit or treatment system vented to a control device, list the device and fill out 

the applicable section of Table 9. Use the same control device codes and format as in footnote 

"h" of Table 2. 

f). Provide the name(s) and other information for any additional wastewater collection unit(s) 

present at the facility. 

g). Provide the name(s) and other information for any additional wastewater treatment unit(s) used 

at the facility. 

% 
11 

EXAMPLE TABLE 6. SEMI-AQUEOUS WASTE COLLECTION AND CONTROL (a) 

Type of Waste 

(b) 

AP 

Bl 

Waste Generation 

Rate 

(tons/year) 

(c) 

10 

12 

Waste Collected in 

a Closed System? 

(Yes/No) 

(d) 

Yes 

No 

Method of On-Site 

Storage 

(e) 

DD 

GG 

Waste Treated or 

Disposed of OnSite? (Yes/No) 

(0 

No 

Yes 

Method of On-Site 

Treatment or 

Disposal 

(g) 

Off-site 

LT 

Control Device on 

Treatment or 

Disposal Unit 

(h) 

N 

N 

See end of table for foomotes. 

co 

ro 
P.83 

12 

EXAMPLE TABLE 6. SEMI-AQUEOUS WASTE COLLECTION AND CONTROL 

(Continued) 

a). Semi-aqueous waste contains any amount of HAP and is between 10 and 90 percent solids. 

b). Select the waste code that best describes the semi-aqueous waste type: 

At? = oil-water separator sludge 

Bl = biotreatment sludge 

HC = contaminated soil 

OD = oily trash and debris 

SO = slop oil emulsions 

SS = sump/sewer clean-out sludge 

B = tank bottoms 

OT = other, please specify (use extra sheet, if necessary). 

c). List the annual semi-aqueous waste generation rate for each type in tons per year (tpy). 

d). Identify (Yes/No) whether the waste is collected in a closed vapor collection system. A closed 

system has equipment to prevent or minimize waste contact with the atmosphere, such as: vapor 

recovery systems, enclosed pipes, or collection units with covers. 

e). Select the storage code that best describes the method by which semi-aqueous waste is stored onsite prior to treatment or disposal: 

AA = open tanks 

BB = fixed roof tanks 

CC = floating roof tanks 

DD = sealed DOT containers (55 gallon drums, 110 gallon bins, etc.) 

EE = open roll-off boxes 

FF = covered roll-off boxes 

GG = open ponds 

HH = covered ponds 

II = open pile 

JJ = covered pile 

OT = other, please specify (use extra sheet, if necessary). 

f). Identify whether waste is treated or disposed of On-Site (Yes) or transported Off-Site (No) for 

treatment and/or disposal. 

g). If waste is treated or disposed of On-Site, select the treatment and/or disposal code(s) that best 

describe(s) how the waste is managed (if more than one code is applicable, separate multiple 

codes with a comma): 

LB = land burial 

LT = land treatment/farming 

DW = dewatering 

ST = solidification/stabilization 

Bl = biotreatment 

W 
P.84 

13 

EXAMPLE TABLE 6. SEMI-AQUEOUS WASTE COLLECTION AND CONTROL 

(Concluded) 

IN = incineration/thermal destruction 

RE = recycled 

OT = other, please specify (use extra sheet, if necessary). 

h). Use thq same control device codes as in footnote "h" of Table 2 or describe other devices on a 

separate sheet. 

n 
P.85 

14 

EXAMPLE TABLE 7. EQUIPMENT LEAK CONTROL DATA 

1. Is there a formal, periodic equipment leak detection and repair (LDAR) program? Yes • No D 

Comments: 

2. Please indicate which Federal/State/local rules require an LDAR program at this facility: 

a). 

b)-_ 

c)._ 

3. If a formal equipment LDAR program has been implemented at your plant, provide the following 

information: 

Definition of a Leak1 

Leak Detection Methodb 

Leak Response Time0 

B 

A 

Begin 5 days, Complete 15 days 

a). Leak definition codes: 

A = 500 ppmv 

B = 1,000 ppmv 

b). Leak detection codes: 

C= 10,000 ppmv 

D = Bubble formation 

A = EPA Method 21 (vapor detector) 

B = Sight (e.g., drips), smell, sound 

C = Gas detection/alarm system 

E = Sensory detection 

OT = Other (specify) 

D = Soap water application 

E = None 

OT = Other 

c). Provide the maximum allowable time after detection to begin and complete repair of a leak. 

%b 
15 

EXAMPLE TABLE 7. EQUIPMENT LEAK CONTROL DATA (Concluded) 

Equipment 

Component 

Valves 

Compressors 

Flanges 

Pumps 

Sampling Connections 

Pressure relief valves 

(to atmosphere) 

Inspection 

Frequency 

(a) 

M 

M 

M 

OT - after 

releases 

Total 

Equipment 

Count 

2,000 

25 

200 

100 

Equipment 

Count in 

LDAR 

Program 

2,000 

25 

200 

100 

Equipment 

Count in 

LDAR with 

HAP Service 

1,000 

15 

100 

100 

Equipment Counts 

with Mechanical 

Control Devices 

(b) 

200 

25 

20 

Equipment Counts with a 

Closed Vent System 

(c) 

Closed Vent 

System Control 

Device 

(d) 

a). Inspection Frequency Codes: 

b). 

c). 

d). 

M = Monthly 

Q = Quarterly 

T = One time only 

OT = Other (specify) 

A = Annually 

E = After equipment change 

Provide equipment counts for equipment in HAP service with mechanical control devices such as: sealless valves, pumps with dual 

mechanical seals and a barrier fluid, compressors with mechanical seals and a barrier fluid, and pressure relief valves with rupture disks. 

Provide equipment counts for equipment with a vapor collection and recovery (closed vent) system. 

Use the same control device codes and formats as in footnote "h" of Table 2. 
P.87 

16 

EXAMPLE TABLE 8. COMPOUNDING/BLENDING/PACKAGING OPERATIONS 

Fait I. 

Product Name 

(a) 

Den. Ethanol 

Ethylene Glycol 

Chemical Composition 

(b) 

Ethanol & Methanol 

Water, Ethy. Glycol 

Annual Quantity 

Produced 

(gal) (c) 

500,000 

2,000,000 

Does a chemical 

reaction take place? 

(d) 

No 

No 

Applicable 

Regulations 

(e) 

None 

None 

a). 

b). 

c). 

d). 

e). 

Provide the product names resulting from blending, compounding, and packaging operations. 

Names must match those provided in Table 1. For families of blends, include only the family 

name listed in Table 1. 

Provide the names ofthe raw materials (must match Table 1) that are used to blend/compound 

the product. 

Provide the annual quantities ofthe products produced. 

Specify whether a chemical reaction takes place during the compounding or blending of organic 

liquids (i.e., yes-compounding, no-blending, etc.). 

Please identify any regulations (pertaining to air emissions) that apply to the 

compounding/blending operation. 

Part II. 

The questions below are facility-wide, and do not need to be answered on a product-by-product basis. 

Please answer the following questions with as much detail as possible. Insert sheets as necessary. 

1. Provide a description ofthe principal methods/mechanisms used for blending/compounding. 

2. Provide a detailed description of any mechanisms of vapor balancing or other vapor emission 

control utilized for these processes (e.g., submerged fill). 

il 
P.88 

17 

EXAMPLE TABLE 9. AIR POLLUTION CONTROL EQUIPMENT PARAMETERS (a) 

Control Device: Scrubber (b) 

Identifier CodefdV Scruhher #1 

Type of scrubber: 

venturi X 

packed bed 

impingement 

other (specify) 

Gas inlet temperature. °F: 75 

Pressure drop, in. H20: 2 

Liquid-to-gas ratio, gal/105 acfin: 1.000 

Inlet scrubbing liquor: 

pH: 2.3 

percent solids: 10 

type of alkali added, if any 

rate (lb/gal) 

Wastewater generation rate, gal/min: 50 

HAP composition of wastewater, mg/l: 20 

Emission Sources (c) 

1. Acrvlate storage tanks 

2. Acrvlate transfer operations 

3. 

4. 

5. 

6. 

See end of table for foomotes. 

W 
P.89 

18 

EXAMPLE TABLE 9. AIR POLLUTION CONTROL EQUIPMENT PARAMETERS (a) 

(Continued) 

Control Device: Incinerator (b) * 

Identifier Code fdV. Incinerator #1 

Type: 

thermal: X 

catalytic: 

Combustion chamber temperature, "F: 1.450 

(please note if temperature measurement is not in chamber) 

Excess air, % 10 

Nominal residence time, s: 1.0 

Heat recovery: 

recuperative, percent heat recovery: ___\ 

regenerative, percent heat recovery 

Emission Sources (c) 

1. 

2. 

3. 

4. 

5. 

6. 

See end of table for foomotes. 

%°\ 
P.90 

19 

EXAMPLE TABLE 9. AIR POLLUTION CONTROL EQUIPMENT PARAMETERS (a) 

(Continued) 

Control Device: Flare (b) 

Identifier Code (d): Fftre#l 

Type: 

no assist: 

steam assist: 

air assist: _X 

pressure assist: 

Location: 

ground: 

elevated: __£ 

Heat content of vented stream, Btu/scf: 300 

Flare gas exit velocity, ft/s: 60 

Flare tip diameter, in. 48 

Flare height, ft 2ft 

Supplementary fuel for: 

pilot, scfm: 6.200 

combustion purposes, scfm 

Steam requirement, lb/hr: N/A 

Emission Sources (c) 

1. Railcar loading (s\ 

2. Excess emissions from AST's. 

3. 

4. 

5. 

6. 

See end of table for foomotes. 

qo 
P.91 

20 

EXAMPLE TABLE 9. AIR POLLUTION CONTROL EQUIPMENT PARAMETERS (a) 

(Continued) 

Control Device: Carbon Adsorber (b) 

Identifier Code fdl: Adsorber ffl 

Type of carbon bed and number: 

regenerative:. 2_non-regenerative: 

fixed:_X. 

fluidized 

How many pounds of carbon per bed: 1.000 

Configuration: 

parallel: X 

serial 

Number of beds on-line 1 

Number of beds desorbing 1 

Pressure drop, in. H-,0: 2 inches 

Gas inlet temperature, °F 75 

Type of regeneration: vacuum 

Regeneration time: 5 min. 

Adsorption time: 20 min. 

Emission Sources (c) 

1. Loading racks 

2. Aviation gasoline loading racks 

3. 

4. 

5. 

6. 

See end of table for foomotes. 

<\\ 
P.92 

21 

EXAMPLE TABLE 9. AIR POLLUTION CONTROL EQUIPMENT PARAMETERS (a) 

(Continued) 

Control Device: Condenser (b) 

Identifier Code fd): Condenser #1 

Type of condenser: 

surface: X 

contact Tif contact, see scrubberl 

Gas inlet temperature, °F 25 

Gas outlet temperature, °F-40 

Emission Sources (c) 

1. Solvents) loading 

2. 

3. 

4. 

5. 

6. 

See next page for footnotes. 

^ 
P.93 

22 

EXAMPLE TABLE 9. AIR POLLUTION CONTROL EQUTPMENT PARAMETERS 

(Concluded) 

a). A separate table should be filled out (after making copies ofthe blank table) for each individual 

scrubber, incinerator, flare, carbon adsorber, or condenser at the facility, unless it is dedicated to 

gasoline service and/or to marine tank vessel loadings. For other types of control devices, 

provide the most important parameters of operation on a separate sheet. 

b). Show ranges, averages, or design values for each parameter and indicate which value is being 

listed. 

c). List specific storage tanks, loading racks/arms, and wastewater and semi-aqueous waste 

treatment or disposal processes, using ID codes and names from Tables 2,3, 5, and 6. 

d). For identifier codes, use the same codes as are listed in Table 2, footnote "h". 

<\3 
Enclosure 2 

EPA's Information Gathering Authority 

Under Section 114 ofthe Clean Air Act 

Under Section 114 ofthe Act (42 U.S.C. 7414), Congress has given the 

U.S. Environmental Protection Agency broad authority to secure information needed "for the 

purpose of (i) developing or assisting in the development of any implementation plan under 

Section 110 or 111(d), any standard of performance under Section 111, or any emission standard 

under Section 112, (ii) determining whether any person is in violation of any such standard of 

any requirement of such a plan, or (iii) carrying out any provision of this Act." Among other 

things, Section 114 authorizes EPA to make inspections, conduct tests, examine records, and 

require owners or operators of emission sources to submit information reasonably required for 

the purpose of developing such standards. In addition, the EPA Office of General Counsel has 

interpreted Section 114 to include authority to photograph or require submission of photographs 

of pertinent equipment, emissions, or both. 

Under Section 114, EPA is empowered to obtain information described by that 

section even if you consider it to be confidential. You may, however, request that EPA treat such 

information as confidential. Information obtained under Section 114 and covered by such a 

request will ordinarily be released to the public only if EPA determines that the information is 

not entitled to confidential treatment.1 Procedures to be used for making confidentiality 

determinations, substantive criteria to be used in such determinations, and special rules 

governing information obtained under Section 114 are set forth in 40 CFR Part 2 published in the 

Federal Register on September 1,1976 (40 FR 36902). 

Pursuant to § 2.204(a) of EPA's Freedom of Infonnation Act (FOIA) regulation, 

in the event a request is received, or it is determined that a request is likely to be received, or 

EPA desires to determine whether business information in its possession is entitled to 

confidential treatment even though no request for release ofthe information has been received, 

please be advised that EPA will seek, at that time, the following information to support your 

claim as required by § 2.204(e)(4) of EPA's FOIA regulations: 

1. Measures taken by your company to guard against undesired disclosure ofthe 

information to others; 

2. The extent to which the information has been disclosed to others, and the 

precautions taken in connection therewith; 

3. Pertinent confidentiality determinations, if any, by EPA or other Federal agencies, 

'Section 114 requires public availability of all emission data and authorizes disclosure of 

confidential information in certain circumstances. See 40 FR 36902 - 36912 (September 1, 

1976). 

M 
P.95 

and a copy of any such determinations, or reference to it, if available; and 

4. Whether your company asserts that disclosure ofthe information would be likely 

to result in substantial harmful effects on the business' competitive position, and if 

so, what those harmful effects would be, why they should be viewed as 

substantial, and an explanation ofthe causal relationship between disclosure and 

such harmful effects. 

15 
P.96 

Enclosure 3 

7042 Federal Register / Vol 58. No. 35 / Thursday. Febraary 2 t 1991 / Notices 

Csted: Ftbtusry It. 1991. 

PaulLapslty, 

Dtntior, Hepilatorr Management Dlrisbn. 

(fR. Doc. 91-4113 Tiled 240-eu 8:48 am) 

IAD-FRL4806-31 

Disclosure of Emission Data Ctahned 

as Confidential Under Sections 110 

and 114(e) ol the Clean Air Act 

AQEMCV: Environmental Protection 

Agency (EPA). 

ACTON: Notice of policy oa public 

release of certain emission data 

submitted under sections 110 and 114(c) 

of tha Qean Air Act (GAA). 

suiniMR Section U4(el of the CAA 

excludes emission data .from the genets! 

definition of trade secret information. 

Certain classes of data submitted to the 

EPA under sections UQ and 114(a) ofthe 

CAA era emission data, and. as such, 

csnnnot be withheld from disclosure ss 

confidential pursuant to section 1905 of 

tide 18 of the United State* Code. This 

notice clarifies EPA'e current policy, end 

solicits comment regarding that policy 

and categories of data which tt 

considers excluded from a trade stent 

definition. 

DATES Written comments pertaining to 

this nodes are requested by April 22, 

1991 

AOOMSSCS: Submit comments to: Nancy 

D. Bilcy, VS, Environmental Protection. 

Agency, Emission Standards Division, 

PoUutant Assessment Branch (MD-13). 

Research Triangle Perk. NC 27711. 

RM FURTHCft INFOMIATION CONTACR 

Timothy Mohln (telephone: (019) 541-

5349 commerdai/FTS 029-6349) or 

Karen Blanehard (telephones (919) 541-

3303 coiametdal/FrS 029-6503), 

PoUutant Assessment Branch (MD-13). 

Emission Standsrds Division: or Thomas 

Rosindahl (telephone: (919) 541-5404 

commercial/FTS 029-5404). National Air 

DaU Branch (MD-14). Technical 

Support Division: U.S. Environmental 

Protection Agency, Research Triangle 

Park. North Caroline. 27711. 

SUmEMEXTARV INRJRSlATlOieThe EPA 

routinely uses-the authority of secUona 

110 and 114(a) of the CAA to gather 

technical Infonnation from Industrie! 

Involved In operations that lead to 

emission of pollutants to the ambient 

air. This infonnation hes been used, 

among other things, to better 

characterise emitting facilities and to 

evaluate the need for and Impacts of 

potential regulation. 

Information requests under sections 

110 and 114(a) or the CAA typically 

Seclude questions on uncontrolled and 

controlled emission rates and emission 

parameters of the pollutant or group of 

pollutants of concern. The respondents 

sometimes claim that IU responsa 

constitutes trade secret infonnatton. and 

thus, should bo treated as confidential. 

Qaimsofconfidentiaiitymsybsmade . 

under section 114(e) of tha CAA. which 

eutes:"* * •noonsshowing 

satisfactory to the Administrator by any 

person that records, reports, or 

infonnation, or e particular part thereof, 

(other than emission data) to which the 

Administrator has access under this 

section if made pubttc would divulge 

methods or processes entitled to 

protection ae trade secrets of tech 

person, the Administrator shall consider 

such* * * confident taeccordance 

with ths purposes of section 1905 of tide 

18 of the United SUtes Cods' • \"lf 

the Administrator so determines, the 

infonnation Is not disdossble to the 

public. 

However, section 114(c) of ths CAA 

provides that Information claimed to be 

e trade secret but which constitutes 

emission data may not be withheld as 

confidential. Although typically .the EPA 

evaluates whether information 

constitutes emission data on a cass-bycast basis. Jt believes that soas kinds of 

daU wul always constitute emission 

daU within the meaning of section 

114(c). The purpose of this nodes is to 

describe, without attempting te be 

comprehensive, that infonnation which 

the EPA generally considers to bs 

emission data, sad which cannot qualify 

as confidential under either section 

114(e) or section 110 (as set forth in 40 

CFR 5U321. 5L322 and 5U23) of tht 

CAA. The EPA is issuing this notice to 

clarify IU policy sod procedures, to 

fadliUte tha use of these daU in 

automated daU systems and computer* 

based simulation models, and to 

expedite processing of claims for 

confidentiality or requesU for 

disclosure. 

The EPA presently determines that 

daU submitted to it as emission data 

does not qualify as confidential if It 

meeU the following definition under 40 

CFR2J01(a)(2)(I): 

a. Definitions. Forthe purpose of this 

section* (l) Act means the Clean Air 

Act. ss amended. 42 U.S.C. 7401 et seq. 

(2)(i) Emiasioa data means, with 

reference to any louree of emlsiton ot 

any substance into tho at*— 

(A) Information necessiry to 

determine tha identity, amount, 

frequency, concentration, or other 

characteristics (to tha extent related lo 

air quality) of any emission which has 

been emitted by the source (or of any 

poUutant resulting from any emission by 

the source), or any combination of the 

foregoing! 

(B) Information necessary to 

determine the identity, amount 

frequency, concentrenon. or ether 

characteristics (to die extant related to 

air quality) ofthe emission which, under 

sa applicable standard or limitation, die 

source was authorized to emit 

(Including, to die extent necessary for 

such purposes, a description of the 

numer or rats of operation of the 

source), or onycoiwMnatfon, of the 

foregoing: 

(C) A general description of the 

location and/or &afnrej of (be source to 

the extent necusaiy to Idr-ntifylhs 

source and to dUdnguish tt hen other 

sources Qnrhidlng. to the extent 

necessary foe such purposes* a 

description of the device, taatauetioo. or 

operation constituting the source). 

The Ublo below lists UM specific data 

fields which tha EPA preaantty 

considers to constitute emission data 

siulprovidesebrief description of what 

each data field describee, the 

descriptions are intended to provide, 

general infernution. This fist Is not ' 

exhaustive end, uereforc, other data 

might be found. In e proper case, to 

' constitute emission data. 

Emission Dsta fields 

Fadlity MmBncatlom The faHowug data 

Odds era needed te establish ufetastttty and 

location of emission sources, tins shall also 

MriodonoesulptiuuoesmtosomnascMtBO 

device, installation, or epsntiea constituting 

the souses. Thcto data en used te local* 

soaxoea tor dispersion evaluation and 

expostm modeling. 

Plant Name and related point Identifiers 

Address 

City 

County 

AQCJt (Alt Quality Control Ration) 

MSA. PMSAwCMSA (Metropolitan SUtiailesi 

Areas) 

Sute 

Zip Code 

Ownership and point of contact information 

LoearJonal Identifiers: 

Latitats A Leagitnd*, or UTM Grid 

Coordinates 

SIC (Standard ladnstrtal eUufleatJocI 

Emission point, devtae or optmflen 

dasenpttoa, tafonaatioti 

SOC (Sow Clsastflmita* Cod—) 

Emissions Parameters! Tho fottowtna d»u 

fletda are needed to eeubliah the 

chsxaatrlaUeaofthanaUslona.Tols 

information is needed tor Ihe analyses of 

dispersion and potential control equipment. 

Emission type 

(ci- nitut* ot emission* such as OO.V, 

paniculate or a aptclAe toxic compound. 

and origin of amissions est* as peseta* 

vanls. itortis tsaka or oqulpraantletk*) 

Emission rats 

% 
P.97 

Federal Register / Vo l 5B, No. 35 / Thursday. February 21.1991 / Notices 7043 

ta-t, ths amount released to the 

atmosphere over time sneh aa kg/yr or 

Ibs/hr) 

Seleses height 

(e-g,nsisM *beve ground ltn& when thspouuttnt la emitted to ti» atmosphere) 

Description of terrain and siuiounding 

Dated: February, e, 1991. 

MIchsel Sharno. 

AetbigAstistaBtAdmiaittmtnrforAJrand 

Rocuatlon. 

(FRDoe. 91-4U4Fusd 2404 s 8AS am) 

tea 

DirtsttFstmsasy tt. 3991. 

Doughs D. Casopt, 

Dbtctot^OJpotefPntitidtPnfpeaBM, 

[FKDoc.8V4l20ni»d2-aO-n:a:4Sainl 

( e » thsstee of ths area associated vi a 

adfacsnl structmes is square meters and 

tsn ^ descriptions suck aa 

. mnmlalnona. urban, ertural) 

Stack or vent diameter st point of emissions 

(eg* the Inside diameter of vent at the 

poird of emission to ths stmosphet* in 

meters) 

Relesss velocity 

(eg . velocily of release m m/sec) 

Release tempsiatuis 

(eg , temperature, et release al point of 

eesssss In oegreea Karvtoj 

Frequency of rslasse . 

(e^hs w often s relesss occurs In evenu 

peryesr) 

DuTstinofrakasa 

(eg* the time assecisted with a relesss to 

uta atmosphere) 

Gormeouuuoe 

(eg* the amount of an emission stream 

constituent relative to omer stream 

constttosnU expresses ss parts pee 

muuoa (ppm). volume penent. or weight 

percent] 

Density of the emissions streamer average 

molecslsr straight 

(eg* density expressed as fraction or 

ranhipIS'.rftASdfmUr/ofslnsioleculsr 

welgUmg/tmoIe) 

Boiler or process design capacity 

(tg , Ihe grau healing vats of fuel input to 

abeflaratttsnmjo^nnmdesianrstsi 

sTw>i«44>t4^n 4^tt^^^f4>m m«i^tiin| 

(is * tita method by which an emission 

rathnste has been calralaird such as 

material balance, source test, use of AP42 emission factors, etc) 

Percent specs best 

(e.g, ths percent of fuel used for spec* 

heating) 

Hourly maximum design sate: 

(04 , ths greetest operating nts thet would 

be expected for a aomxs in a 1-hour 

psriedl 

The EPA has determined that these 

data are emission daU and releaaable 

upon request This determination 

applies to data currently held by EPA a s 

well ea to infonnation submitted to .EPA 

In the future. Future requesU for 

information under sections UO end 114 

of the CAA will Indicate that these 

emission dale will not bs held 

confidential Thia determination applies 

only to the dsta listed in tha table. 

Determinations will continue to be made 

o n a ctae-by-caae basla for data not 

specified In thia generic determination. 

•After consideration of comment a on 

this policy, a revised policy/ 

determination may be published. 

(OPP-200000A;FRL-3S79-<1 

Reo^estforf^ropoes^Reeearchand 

DevetoproertonArritaslerobbsJ^ 

•UtethtxtokwutdSasttstlcal Support 

mtixpeiimerrtatOesionsndOsia 

Analysis; Prtsnilonct Proposal 

Deadline 

AftiMCifs Emrlrtminental Protection 

Agency (EPA). 

ACTIQW Extension of proposal deadline. 

aoatssasre This notice aimnrnices the 

extension of deadline for a Request for 

Proposal that published In da Federal 

Register of December 8.1990. The 

Request for .Proposal was published to 

solicit propossls which will result In the 

development of a reproducible, reliable, 

and sUtistlcally valid sporiddal test 

melhod used to evaluate the efficacy of 

antimicrobial products hearing sterilizer 

or sporiddal claims. In addition. 

proposeJsfarstetJsticoltapportto 

independently evaluate the 

experimental designs of projects and to 

analyze reetdUfrmn on>going test 

methodology research were also 

solicited. 

OATESS The new deadline for proposal 

submission to the Agency is February 

28,1981. 

ADoaesscssThe original and eight 

copies must be sent to: Grants 

Operations Branch (PM-216F). 

Environmental Protection Agency. 401M 

SL, SW, Washington, DC 20*00. One 

copy of the original must be sent to: 

SussnPsrker. Registration Division • 

(H7S0SC), Environmental Protection 

Agency, 401M SU SW„ 20450. 

Application Kits may be obtained from: 

GranU Operations Branch (PM-aeF)> 

Environmental Protection Agency, 401M 

SUSW,Wuriing1on.DC2D»aarcall: 

(202) 382-5280. 

ran FURntan INFORSJATIOM COHTACT: 

Susan Parker. Registration Division 

(K7SQ5Q. Environmental Protection 

Agency. 401M St, SW, Washington, DC 

20460. Phone number (703) 587-4141. 

SUPPLEMENTARY INTOMUTWt* EPA 

Issued a Request for Prepoeai in the 

Federal Register of December 0.1990 (55 

FR S038B). Tha original submission 

deadline was January Mt 1991: the new 

deadline for proposal submission ia 

extended to February 28,1901. 

[OPP-ieoe4UFRLr3Sn-«l 

AQSNort Environmental Protection 

Agency (EPA). 

Acnote Notice. 

simtiarmEPAhas granted specfBe 

«0(aUBOtawOai sHsffeDel CBBTHM ttf ^n^ptTesmsn 

paste to the seven States e s Bated below 

and one by the United States 

Department of Agrituluua. Four crisis 

exemptions were Initiated, tsro by die 

Florida Deysitinent of Conseeser 

Scnrtm and tare by ttttUhfisri Statu 

exemptions. Issued thrrfwg dre months of 

November endDetmmben except for the 

GBB IB RjCtOOCft eaUasI SW»0BVG% vB 

application and timing restrictions end 

teputuM tcquueitieitls designed to 

protect the environment to the maximum 

extent possible. Ldormsilon oa these 

restrictions Is svsJuoIa from the contact 

personstoEPAllsted below. 

OATIS: See each spectBe and crista 

exemption for lis effective date, 

post ruatWEa mnMuiwH coevAcn 

See eech emergency exemption for the 

following information applies te all 

contact persons: «By male Registration 

Division (H750SCL Office of Pesticide 

Programs, Environmental Protection 

Agency. 4m MSUSW^ Washington. DC 

20460. Office location and telephone 

number: Rm. 718, Chi #2,1921 [efierson 

Davis Highway, Arlington, VA. (705-

557-1808). 

SUPnaVCNTAItV tNFORSSATION: EP A bs s 

granted specific exemptions t o the. 

1. California Department of Food and 

Agriculture for the use of duorodtalotul 

on mushrooms to control vettidlllum 

diseases: November 14,1990, to 

November 13,199L (Susan Stanton) 

2. Califomia Department of Food and 

Agriculture for die us e of avenaectin Bi 

on celery to control aerpentlao 

leafminers: November 19.1990. ta 

November IB. 199L (Zibby Pemberton) 

3. California Department of Food and 

Agriculture for die use o t methyl 

bromide on carrots to control 

nematodes; December 21.1990, ta 

December 20,1991, (Ubby Pemberton) 

4. Idaho Department of .Agriealture for 

ths us* of pendimetivaHn o n epenrmtnt 

and peppennint to control koehin and 

m 
P.98 

5» | ' ^ * '£ UNITED STATES ENVIRONMENTAL PROTECTION AGENCY tnClOSUre4 

I XUA Z 2 RESEARCH TRIANGLE PARK. NC 27711 

^PP 1 ? IOO"' OFFICE OF 

O t T » C '*. AIR QUALITY PLANNING 

ANOSTANOARDS 

DESIGNATION OF AUTHORIZED REPRESENTATIVE 

FOR STANDARDS OF PERFORMANCE FOR NEW STATIONARY SOURCES 

(SECTION 111) AND SOLID WASTE COMBUSTION (SECTION 129) , • 

NATIONAL EMISSION STANDARDS FOR HAZARDOUS AIR POLLUTANTS 

(SECTION 112) , AND FEDERAL OZONE MEASURES (SECTION 183) 

Under contract 68D60013, Pacific Environmental Services (PES) 

(prime contractor) and Alpha-Gamma Technologies, Incorporated 

(subcontractor) are hereby designated Authorized Representatives of 

the Administrator of the United States Environmental Protection 

Agency for the purpose of assisting in the development of national 

emission standards for hazardous air pollutants under 42 U.S.C. 7412, 

standards of performance for new stationary sources under 42 U.S.C. 

7411, solid waste combusion under 42 U.S.C. 7429, and Federal ozone 

measures under 42 U.S.C. 7511 (b) . 

This designation is made pursuant to the Clean Air Act, 

42 U.S.C. 7414. The United States Code provides that, upon 

presentation of this credential, the Authorized Representatives named 

herein: (l) shall have a right of entry to, upon, or through any 

premises in which an emission source is located or in which records 

required to be maintained under 42 U.S.C. 7414 (a) (1), are located, 

and (2) may at reasonable times have access to and copy any records, 

inspect any monitoring equipment or method required under 42 U.S.C. 

7414 (a) (l), and sample any emissions that the owner or operator of 

such source is required to sample. 

Authorized Representatives of the Administrator are subject to 

the provisions of 42 U.S.C. 7414 (c) respecting confidentiality of 

methods or processes entitled to protection as trade secrets, as 

implemented by 40 CFR 2.301 (h) (41 FR 36912, September 1, 1976). 

Date: 

Designation Expires: September 30, 1998 

Seitz 

>irector 

Office of Air Quality Planning 

and Standards 

(\% 
P.99 

Enclosure 5 

December 1995 

Summary of QAQPS 

Procedures for Safeguarding Clean Air Act (CAA) 

Confidential Business Information (CBI) 

1. Purpose 

This memorandum describes Agency policy and procedures pertaining to the handling 

and safeguarding of information that may be entitled to confidential treatment for reasons of 

business confidentiality by the OAQPS, Office of Air and Radiation, U.S. Environmental 

Protection Agency. 

2. Other Applicable Documents: 

a. Clean Air Act as amended. 

b. 40 CFR, Chapter 1, Part 2, Subpart B - Confidentiality of Business Information. 

c. EPA Security Manual, Part II, Chapters 8 and 9. 

d. Clean Air Act Confidential Business Information Security Manual (June 1995 

edition). 

3. Exception: 

This document was prepared as a summary of data gathering and handling procedures 

used by the OAQPS, EPA. Nothing in this document shall be construed as superseding or being 

in conflict with any applicable regulations, statutes, or policies to which EPA is subject. 

4. Definition: 

Confidential Business Information - Information claimed by the provider to be 

confidential. This information may be identified with such titles as trade secret, secret, 

administrative secret, company secret, secret proprietary, privileged, administrative confidential, 

company confidential, confidential proprietary, or proprietary. NOTE: These markings should 

not be confused with the classification markings of National Security information identified in 

Executive Order 11652. 

5. Background 

Section 114 (c) ofthe Clean Air Act as amended reads as follows: 

<rt 
p.1 

"Any records, reports, or information obtained under subsection (a) shaft be 

available to the public, except that upon a showing satisfactory to the 

Administrator by any person that records, reports, or information, or particular 

part thereof, (other than emission data) to which the Administrator has access 

under this section if made public, would divulge methods or processes entitled to 

protection as trade secrets of such person, the Administrator shall consider such 

records, report, or information or particular portion thereof confidential in 

accordance with the purposes of Section 1905 of Title 18 of the United States 

Code, except that such record, report, or information may be disclosed to other 

officers, employees, or authorized representatives ofthe United States concerned 

with carrying out this Act or when relevant in any proceeding under this Act." 

The treatment of CBI by the U.S. EPA, including data obtained under Section 114 of the 

Clean Air Act, is governed by Title 40, Part 2, ofthe Code of Federal Regulations. These 

regulations require EPA offices to include a notice with each request for information to inform 

the business of (1) its right to assert a claim of confidentiality covering part or all of the 

information, (2) the method for asserting a claim, and (3) the effect of failure to assert a claim at 

time of submission. In addition, the regulations: (1) set forth procedures for the safeguarding of 

confidential information; (2) contain provisions for providing confidential information to 

authorized representatives; (3) contain provisions for the release of information to the Congress, 

Comptroller General, other Federal agencies, State and local governments, and Courts; (4) permit 

the disclosure of information within EPA to employees with an offieial need for the information; 

and (5) prohibit wrongful use of such information and cite penalties for wrongful disclosure. 

Further, the regulations contain the Agency's basic rule concerning the treatment of requests for 

information under the Freedom of Information Act (5 U. S.C. 552). 

6. Procedures: 

a. Request for Information 

Each request for information made under the provisions of Section 114(a) is signed by the 

Division Director. The request includes standard enclosure "EPA's Information Gathering 

Authority Under Section 114 ofthe Clean Air Act," which was designed to meet the requirement 

of 40 CFR Part 2 discussed above. 

b. Receipt of CAA Confidential Pusfoess information 

Upon receipt of information for which confidential treatment has been requested, the 

Office ofthe Director (OD) directs the logging ofthe material and the establishment of a 

permanent file. If confidential treatment is requested, but is not specifically marked, the material 

will be stamped "Subject to Confidentiality Claim." If part ofthe material is claimed to be 

confidential, that portion is marked "Subject to Confidentiality Claim." In compliance with 

[00 
P.2 

Sections 2.204 and 2.208 of 40 CFR Part 2, the Group Leader responsible for the requested 

information reviews the information to determine whether it is likely to be confidential in 

contrast to being available in the open literature, whether it is emission data, and whether it likely 

provides its holder with a competitive advantage. If the information is clearly not confidential, 

the Group Leader prepares a letter for signature ofthe Division Director, ESD, to notify the 

business of this finding. If the information is possibly confidential, the Group Leader sends a 

memorandum to inform the OD, ESD, of this finding, gives a brief description ofthe material 

(what it is, how many pages, etc.), identifies it with the correct ESD project number, and lists 

those persons who are authorized to have access to the information. The information and 

memorandum are hand carried to the OD and placed in the CBI files with the material. A record 

of who will see the information (Attachment A) is also filed with the folder containing the 

information. If CAA CBI is received from the owner via an authorized representative or a third 

party, the same procedure is followed, with the addition of clearly identifying the information 

and its source. By regulation, information for which confidential treatment is requested must be 

so marked or designated by the submitter. The EPA takes additional measures to ensure that the 

proprietary designation is uniformly indicated and immediately observable. All unmarked or 

undesignated information (except as noted below) is freely releasable. 

c. Storage of CAA Confidential Business Information 

Folders, documents, or material containing CAA CBI (as defined) shall be secured, at a 

minimum, in a combination-locked cabinet. Normal procedure is to secure this information in a 

cabinet equipped with a security bar and locked using a four-way, changeable combination 

padlock. In addition, the entrance door to the CBI storage room is equipped with a changeable 

combination simplex lock. The locked files are under the control ofthe OD. 

Knowledge ofthe combinations ofthe locking devices is limited to the Document 

Control Officer (DCO) and the minimum number of persons required to effectively maintain 

normal business operations. Records ofthe locking device combination are stored elsewhere in 

conformance with the requirements ofthe EPA Security Manual. 

Combinations ofthe locks are normally changed whenever a person with knowledge of 

the combinations is transferred, terminates employment, no longer authorized access, or 

whenever the possibility exists that the combinations may have been subject to compromise. 

Files may be checked out upon confirmation that the requesting person is authorized to 

receive the information. All confidential files may be returned no later than 4:30 p.m. on the 

same day they are removed. The intended user must sign the CBI Control Record when the file 

is checked out. 

The individual who signs out a confidential file is responsible for its safekeeping. The 

file must not be left unattended. The information must not be disclosed to any non-authorized 

personnel. 

/Ol 
P.3 

Storage procedures for CAA CBI by an authorized representative of EPA (see Section d. 

below) must be, at a minimum, as secure as those established for EPA offices within OAQPS. 

Whenever CBI is removed from the EPA files to be transmitted to an authorized representative, 

notation is placed in the file indicating what information was transmitted, the date, and the 

recipient. The authorized representative returns a signed receipt ofthe DCO. 

d. Access to CAA Confidential Business Information 

Only authorized EPA employees may open a distribute CAA CBI. 

Only employees who require and are authorized access to CAA CBI in the performance 

of their official duties are permitted to review documents and, upon receiving a confidential 

document, must sign and date the form shown in Attachment A to certify their access to the 

document. 

The CBI files are controlled by the OD, ESD, and managed by an authorized federal 

employee. Access to the information is limited to those persons having a need to know in 

performing their official duties. 

The Group Leader having primary interest in the CAA CBI provides a memorandum for 

the record designating those personnel who are authorized to use CBI in a program under which 

CBI can be requested. No person is automatically entitled to access based solely on grade, 

position, or security clearance. The names of persons granted access to CAA CBI are placed on 

the Clean Air Act CBI access list, which indicates the "specific" CBI each person is permitted to 

see. The Access List is reviewed and updated periodically. 

Companies under contract to perform work for the EPA may be designated authorized 

representatives of EPA if such designation is necessary in order for the contractor to carry out the 

work required by the contract. As authorized representatives, contractors may be granted access 

to CAA CBI by the Director, ESD. The following conditions apply when it has been determined 

that disclosure is necessary: 

(1) The contractor designated as a representative and its employees (a) may use such 

confidential information only for the purpose of carrying out the work required, (b) must refrain 

from disclosing the information to anyone other than EPA without having received from EPA 

prior written approval of each affected business or of an EPA legal office, and (c) must return to 

EPA all copies ofthe information (and any abstracts or excerpts therefrom) upon request or 

whenever the information is no longer required for the performance ofthe work. 

(2) The authorized contractor designated as a representative must obtain a written 

agreement from each of its employees who will have access to the information. A copy of each 

employee agreement (Attachment B) must be furnished to EPA before access is permitted. 

101 
P.4 

(3) The contractor designated as an authorized representative must agree that the 

conditions in the contract concerning the use and disclosure of CAA CBI are included for the 

benefit of, and shall be enforceable by, both EPA and any affected business having a proprietary 

interest in the information. 

Information may be released to or accessed by EPA employees other than OAQPS 

employees only upon approval ofthe Director, ESD. 

Requests for CAA CBI from other Federal agencies, Congress, the Comptroller General, 

Courts, etc., are processed by the OD, ESD in accordance with 40 CFR 2, Subpart B. 

Requests under the Freedom of Information Act are handled in accordance with 40 CFR 

2, Subpart A. The Freedom of Information Act Coordinator must be consulted prior to 

responding to any request for information if a claim of confidentiality has been asserted or if 

there is reason to believe that a claim might be made if the business knew release was intended. 

e. Use and Disclosure of CAA Confidential Business Information 

The CAA CBI as defined may not be used in publications, supporting document, 

memoranda, etc., that become a part ofthe public domain, except as provided for in 40 CFR 2 

Subpart B. 

The CAA CBI may not be summarized without the approval ofthe Group Leader 

responsible for the CAA CBI. Any authorized reproductions must be logged into the CAA CBI 

document tracking system and treated according to the same procedures applicable to the original 

confidential material. 

The EPA generated documents or material, or extracts of information containing CAA 

CBI, must be stamped "Subject to Confidentiality Claim" and a cover sheet must be attached to 

identify the material as CBI. 

f. Handling of Other Information 

Reports, memoranda, documents, etc., prepared by EPA or its authorized representatives 

are not normally circulated outside EPA for comment or review prior to publication except in 

such cases as described above (6.d.3) wherein CBI is expressly included. However, because 

industrial-data-gathering visits, plant inspections, and source testing can involve inadvertent 

receipt of CAA CBI, it is the policy of OAQPS to protect all parties involved in the following 

manner. 

Prior to or at the inception of a plant inspection, data-gathering visit, or source test, EPA 

or its authorized representative discusses with a responsible industry official the information 

sought, how it is to be used, and how it is to be protected. A copy of this summary is usually 

/03 
P.5 

provided to the industry official being consulted. 

Following an inspection, visit, or test, a trip report is prepared to include, as practicable, 

all information received by EPA or its authorized representative during the visit or test. The 

report may be prepared by either EPA or its authorized representative. The draft of that report is 

clearly identified, on an attached, colored cover sheet as "Confidential Pending Determination." 

A second copy ofthe draft trip report is forwarded by EPA to the responsible industry official for 

review. The responsible industry official is requested by cover letter to review the report, clearly 

mark any information considered to be confidential, and return the marked up-report to the 

responsible EPA employee within 2 weeks of receipt. The original draft is kept in the CBI 

"pending" file until the marked-up copy is returned by the business firm. 

When the reviewed copy ofthe report, as marked by the responsible plant official, is 

received by EPA, information designated confidential is placed in the CBI files as described 

above. The original draft ofthe trip report is edited to delete the confidential information and to 

accommodate technical changes, and the trip report is issued. 

2 Attachments 

\<n 
P.6 

Attachment A 

CAA CONFIDENTIAL BUSINESS INFORMATION 

CONTROL RECORD 

DATE RECEIVED: 

DATE OF DOCUMENT: 

RESPONSIBLE BRANCH: CONTROL NUMBER: 

DOCUMENT AUTHOR: 

DESCRIPTION (Providing organization, title, subject, number of copies and number of pages) 

RETURN DATE: DESTRUCTION DATE: INITIALS: 

Each person given access to this document must fill in the information below 

CHECK-OUT 

SIGNATURE DATE TIME 

* 

CHECK-IN 

SIGNATURE DATE TIME 

CAA CBI Form 1 (Rev. 6/95) 

105 
P.7 

Attachment B 

I. AUTHORIZATION FOR ACCESS TO CAA CBI FOR CONTRACTOR EMPLOYEES 

FULL NAME 

SSN 

POSITION 

CONTRACTOR 

It is the responsibility of each Authorizing Official* to ensure that the employees under his/her supervision who 

require access to CAA CBI: 

1. Sign the Confidentiality Agreement for EPA Employees 

2. Are fully informed regarding their security responsibilities for CAA CBI 

3. Obtain access only to that CAA CBI required to perform their official duties 

SIGNATURE OF AUTHORIZING OFFICIAL* 

TITLE 

TELEPHONE NO. DATE 

LOCATION 

II. CONFIDENTIALITY AGREEMENT FOR CONTRACTOR EMPLOYEES 

I understand that I will have access to certain Confidential Business Information submitted to EPA or its 

authorized representatives under the Clean Air Act (CAA). This access is granted in accordance with my official 

duties as an employee ofthe Environmental Protection Agency contractor. 

I understand that CAA CBI may not be disclosed except as authorized by CAA and Agency regulations. I 

understand that I am liable for a possible fine of up to $1,000 and/or imprisonment for up to 1 year if I willfully 

disclose CAA CBI to any person not authorized to receive it. In addition, I understand that I may be subject to 

disciplinary action for violation of this agreement with penalties ranging up to and including dismissal. 

I agree that I will treat any CAA CBI furnished to me as confidential and that I will follow the procedures set 

forth in the CAA Confidential Business Information Security Manual. 

I have read and understand these procedures. 

SIGNATURE TELEPHONE NO. DATE 

III. HAVING COMPLETED REQUIRED TRAINING AND PASSED REQUIRED TEST, THE 

ABOVE-NAMED EMPLOYEE IS HEREBY AUTHORIZED TO HAVE ACCESS TO CAA CBI. 

SIGNATURE CONTRACTOR/DCO TELEPHONE NO. DATE 

* Must be Contractor Management 

CAA CBI Form 3 (Rev. 6/95) 

^ y