P.1 

OAR Box 1669 

Prepped by Charmelle Mathews 

Document Number: 

fjrf) U-EA9 

Docket Number: 

A-98-13 

Printed 9/23/2008 9:36:49 AM Sheet 87 of 110 
l_l 

P.2 

MEMORANDUM 

TO: Martha Smith 

U.S. EPA/OAQPS/ESD/WCPG 

ESD Project No. 96/05 

FROM: Greg LaFlam and Bernd Haneke s&Cl&C 

Pacific Environmental Services, Inc. (PES) 

DATE: October 20,1999 

P:\n831 

SUBJECT: October 5,1999 Fourth Roundtable Meeting for the Organic Liquids 

Distribution (non-Gasoline) (OLD) MACT Rule 

I. Purpose 

The purpose of this meeting was to bring together the stakeholders for the OLD project, 

including the U.S. Environmental Protection Agency (EPA) and its contractor, to discuss the 

analysis of survey data, MACT floors, and preliminary rule provisions and impacts. This work 

is in support of the development of national emission standards for hazardous air pollutants 

(NESHAP) for the OLD source category. 

II. Location and Date 

U.S. Environmental Protection Agency 

Environmental Research Center (ERC), Classroom #1 

Research Triangle Park, North Carolina 

October 5,1999,9:00 am to 2:30 pm 

III. Participants 

In person 

Bill Beck, Mobil Oil 

Laura Burrell, Chemical Manufacturers Association 

David Darling, National Paint and Coatings Association 

Bernd Haneke, Pacific Environmental Services, Inc. (PES) 

Kent C. Hustvedt, EPA 

Paul Jann, Dupont 

Greg LaFlam, PES 

Tara Lanier, Ashland Chemical Company 

Robert Matejka, Akzo Nobel Coatings 

Jack McClure, Shell Chemical 

Usha Mehra, GATX Terminals 
P.3 

Memorandum - 4th Roundtable 

October 20, 1999 

Page 2 

Denise Michelson, ARCO 

Norm Morrow, Exxon Chemical 

Liane Piatt, Dow Chemical 

Karin Ritter, American Petroleum Institute 

Martha Smith, EPA 

Larry Sorrels, EPA 

Hal Taback, Hal Taback Company 

Don Wang, Union Carbide 

Gary Wilson, Marathon Oil Company 

Rick Wright, Ashland Chemical Company 

Phone-in 

Jordan Jacobsen, Alyeska Pipeline Service Company 

David Mazzocco, PPG 

Jackie Surles, Louisiana DEQ 

Jan Werner, Marathon Ashland Petroleum 

The complete project stakeholder list, indicating which members attended the meeting, is 

included as Attachment 1 to this memorandum. The EPA's presentation on the status of the 

rule proposal is Attachment 2, and the EPA's economics presentation is Attachment 3. 

IV. Summary of Discussion 

The principal discussion topics at the meeting are summarized below. Page numbers 

refer to the page in the EPA's presentation on the rule status (Attachment 2). Action items 

agreed to by the stakeholders and the EPA are listed separately following the summary. 

1. Survey Coverage/Scope of Industry 

All major source refineries with OLD operations should have been caught in the survey; 

the segment responding (p. 6) is shown by the EPA as only 30 percent. Using that assumption, 

baseline emissions and impacts may be overstated (Mobil/API). 

The EPA's estimate of the number of major source chemical production facilities (p. 6) 

may be based on an outdated reference source. An updated listing of the sources subject to the 

HON is being prepared by industry and should be released in 4 to 6 weeks (CMA, Dupont, 

Exxon Chemical). 

What types of facilities are included in the term "for-hire" terminals (p. 6) (Taback 

Company)? EPA: Normally those non-collocated terminals handling liquids owned by others. 

Attendees stressed that the line between for-hire and other terminals is blurred, with chemical 
P.4 

Memorandum - 4th Roundtable 

October 20, 1999 

Page 3 

companies leasing out storage space at their own stand-alone terminals, etc. (Shell Chemical, 

Exxon Chemical, Dupont). EPA: The labels used on the table are for convenience, and are not 

expected to be used in the rule. 

2. Regulatory Cutoffs 

Does the 5 percent HAP cutoff defining organic liquids (p. 15) apply to the entire liquid 

(example, coatings that have both liquid and solid components) or just to the volatile fraction 

(PPG)? EPA: Cutoff applies to the entire liquid. 

Where did the 5 percent cutoff come from (API)? This cutoff seems too low; a 10 

percent value is used in the benzene rules (GATX). EPA: It is a working number that has been 

used in other rules, notably the HON. We are still analyzing whether it is the most appropriate 

value. 

For-hire terminal facilities will not be able to determine HAP percentages in the liquids 

they handle, because precise data are not typically provided to them by clients (GATX). EPA: 

Would it be feasible for facilities to require more exact data from the liquid owners? No, this 

would not be practical (GATX). 

We suggest that all applicability cutoffs (tank size, vapor pressure, and liquid 

throughput) be placed in the Applicability section of the rule (API). EPA: The EPA is 

requesting input to aid in the development of reasonable cutoffs, and will attempt to consolidate 

cutoffs to make the rule easier to understand. 

3. Table of Affected HAP 

What was the source of the vapor pressure data used to create the HAP table (p. 17-19)? 

Why was 25 degrees C used as the basis; this seems high in relation to actual liquid 

temperatures and affects which HAP are placed on the list. Perhaps 20 degrees C would be a 

more appropriate choice (Mobil/API). EPA: An EPA contractor (RTI) collected and supplied 

these data, using 25 degrees C as the basis. We will review the basis for this choice. 

Which glycol ethers are supposed to be included on the table, and which are excluded 

(p. 18) (Akzo Nobel Coatings)? EPA: Specific glycol ethers meant to be on this table will be 

specifically listed when the table is published. 

4. Storage Tanks 

Stakeholders addressed several tank issues, mainly dealing with exclusions, compliance 

time, etc. These are covered under items 9 and 10 on exclusions and other rule provisions. 
P.5 

Memorandum - 4th Roundtable 

October 20, 1999 

Page 4 

The costing methodology for storage tank control installation (floating roofs) may 

underestimate the actual costs, due to certain items that the EPA disregards in its assumptions, 

such as siting for the tank, etc. (Dupont). 

5. Loading Racks/Cargo Tanks 

Shouldn't the 20 ppmv alternate emission limit (p. 11,20) be applicable to noncombustion type devices, as is provided in some other rules (Dupont)? EPA: We are not aware 

of any demonstration of this being an appropriate alternative for non-combustion control 

devices. 

EPA: Does industry prefer a facility-wide or a per-rack throughput cutoff for 

applicability? Consensus apparently was that each rack should have a cutoff, to allow owners 

to designate a type of service for a rack and only control those meeting the OLD criteria. 

What test methods would be specified for the annual cargo tank vapor tightness 

certification? Attendees expressed a preference for having a choice between EPA Method 27 

and the present DOT tests affecting chemical tank trucks (Exxon Chemical, Dow Chemical, 

NTTC following meeting). EPA: Method 27 would apply to tank trucks equipped with a vapor 

collection system; other trucks will probably be allowed to continue using the DOT methods. 

6. Containers 

Emissions from container filling are very low per the EPA's estimate (NPCA). The 

submerged fill approach could lead to increased emissions in many cases due to liquid clinging 

to the fill tube when it is removed from the container. Also, cleaning these tubes could produce 

hazardous waste at the facility (Ashland Chemical, Exxon Chemical). The loader would have 

to absorb the control costs; the EPA should look seriously at whether these controls would 

produce a benefit (Akzo Nobel Coatings). 

There are not many drums that are exactly 55 gallons; they vary in size above and below 

this size. The EPA should not regulate nominal 55-gallon drums (Akzo Nobel Coatings). 

There are many low-volume, intermittent drum fillings that occur at liquid handling 

facilities. A low-volume throughput applicability cutoff is needed. Special purpose fillings 

(example, spill response, samples, maintenance) should also be excluded (Exxon Chemical, 

Dow Chemical, Dupont, Shell Chemical). 

7. Equipment Components 

The estimated costs and baseline emissions for equipment components appear to be very 

•V 
P.6 

Memorandum - 4th Roundtable 

October 20, 1999 

Page 5 

high. EPA: There are two potential reasons: some reported equipment counts appeared to be 

too high due to possible misinterpretation by survey respondents, and emission factors derived 

for SOCMI operations were used to calculate the baseline emissions and emission reductions. 

The CMA offered to assist in contacting individual facilities with extremely high counts. In 

response to a question, the EPA stated that a combination of with-LDAR (controlled) and noLDAR (uncontrolled) emission factors were used in calculating the baseline. The EPA should 

use the lower marketing facility emission factors, previously accepted by the EPA for gasoline 

marketing facilities, for similar facilities under consideration in the OLD category (Marathon). 

EPA: Do these factors apply only to gasoline handling equipment? These factors are not 

necessarily restricted to gasoline equipment (Mobil/API). 

Some equipment components at terminals are in intermittent use, so baseline emissions 

(p. 8) may be lower than the EPA estimated (GATX). EPA: Is this equipment purged of HAP 

between uses? The answer to this question was unclear. 

What specific data should industry submit to demonstrate that a visual inspection 

program would be as effective in detecting leaks from equipment as an instrument-based LDAR 

program (GATX)? GATX could collect data for terminals in Texas; the '93-94 data should 

reflect the leak rate existing prior to adoption of instrument LDAR by the State. EPA: These 

data will be useful in comparing the effectiveness of the two control approaches. 

8. Applicability/Covered Operations 

The rule should provide a separate subcategory and requirements for the for-hire 

terminal industry segment, at least in terms of controls for equipment components (GATX). 

What will be the rule criteria defining a major source? The EPA survey used an actual 

emissions cutoff of 5/12.5 tons per year, while the usual measure in MACT rules is a potential 

to emit (PTE) of 10/25 tons per year. The use of the PTE approach would lead to coverage of 

many more for-hire terminals due to the flexibility that these facilities need in their operations. 

We prefer the use of an actual emissions cutoff, similar to the Marine Loading MACT rule 

(GATX). The EPA's transition policy on PTE could be referenced in the Applicability section 

if the actual emissions approach were selected (Mobil/API). EPA: No formal decision on this 

issue has been made. 

EPA: If an owner is leasing space to other companies on its plant site, should all HAP 

emissions be aggregated to determine the major source status? We have such a leasing 

arrangement at one of our facilities (Ashland Chemical). See the Marine Loading MACT rule 

for a treatment of multi-owner sites (Dow Chemical). 

_r 
P.7 

Memorandum - 4th Roundtable 

October 20, 1999 

Page 6 

9. Suggested Exclusions 

Include a rule exclusion for on-site transfers and transfer of waste liquids. Or, include 

an exclusion for RCRA-covered wastes. Consider the RCRA definition of waste (Exxon 

Chemical). 

Exclude Research and Development (R&D) activities from coverage. These divisions 

sometimes use market development tanks in evaluating new products (Dow Chemical). 

Exclude pressure vessel storage (C4 and lighter products, may have emergency releases) 

(Exxon Chemical). 

The EPA agreed that these suggestions may be valid, and said they would consider them 

in drafting the proposed rule. 

10. Other Suggested Rule Provisions 

The new generic (G-) MACT subparts are preferable generally to the HON for similar 

emission sources due to the burden reduction resulting from improved administrative 

requirements in these new subparts. Alternatively, we would like to have the option of 

choosing either the HON or the G-MACT provisions. The tank Level 2 requirements and 

subparts TT and UU for fugitives were cited as specific improvements (Shell Chemical, Exxon 

Chemical, Dow Chemical). EPA: Is there a downside to referencing existing rule provisions? 

Attendees responded that the General Provisions are different among rules that are in different 

parts of the CFR (i.e., parts 60, 61, and 63). 

A low-throughput applicability cutoff is needed for the container filling provisions in 

the rule (Exxon Chemical). 

For storage tanks with variable use, a predominant use provision is needed, so that 

occasional or one-time uses of a tank for organic liquids does not trigger applicability (Exxon 

Chemical). Also, with the MTBE phaseout many tanks will be changing their service to lower 

HAP content liquids. The EPA should check recent MACT rules (example, Pharmaceuticals) 

that deal with flexible operation (ARCO). 

Allow the longer compliance periods to perform tank conversions (example, 10 years), 

as in many other rules, to avoid the cleaning/degassing emissions that may exceed the emission 

reductions from the controls (Shell Chemical). 

Specify in the container filling standards that they apply to the drumming of products, to 

eliminate any confusion over the treatment of waste (Exxon Chemical). 

2. . 
P.8 

Memorandum - 4th Roundtable 

October 20, 1999 

Page 7 

11. Miscellaneous Organic NESHAP (MON) Rule Coordination 

Clarify the current status of the coordination of the OLD rule with the MON (NPCA). 

EPA: The approach will be for the MON to cover all OLD-type emission sources at MON 

facilities using the same emission standards as are in the OLD MACT. This will primarily 

come into play with regard to certain storage tanks and in product loadout, where containers 

and cargo tanks are filled with organic liquids for distribution off the plant site. 

12. Economics Presentation 

One attendee asked Mr. Sorrels about how a small entity is defined for the economic 

analysis. Mr. Sorrels replied that the Small Business Administration applies criteria that, for 

this category, would include primarily the number of employees in the parent company. 

13. Action Items 

The EPA and stakeholders agreed to provide information to each other to assist in the 

rule development and to answer questions. 

Items that the EPA agreed to provide to stakeholders: 

1. Provide to API the complete list of HAP from which the HAP table (p. 17-19) was derived. 

Provide the reference for the table's vapor pressure data to Mobil/API. 

2. Provide to CMA a list of facilities that submitted very high equipment counts in response to 

the EPA's 1998 survey. 

3. Provide GATX with a detailed data base output regarding equipment leak rules in effect at 

the SIC code 42 facilities (primarily for-hire terminals) that responded to the EPA survey. 

Items that stakeholders agreed to provide to the EPA: 

1. List of HON-covered major source facilities (CMA, Exxon Chemical). 

2. Data related to cargo tank testing methods in use (Exxon Chemical). 

3. Examples of exclusions contained in container filling rules (example, transfers related to spill 

response, etc.) (Exxon Chemical). 

4. Listing of State/local throughput cutoffs in liquid transfer regulations (cargo tank and other 

containers) (Ashland Chemical). 

1 
P.9 

Memorandum - 4th Roundtable 

October 20, 1999 

Page 8 

5. Equipment leak results for Texas facilities under various control programs (visual 

inspections, instrument LDAR) (GATX). 

1 
P.10 

Memorandum - 4th Roundtable 

October 20, 1999 

Page 9 

Attachment 1 - Stakeholder/Attendance List 

•3 
Organic Liquids Distribution (non-Gasoline) MACT 

Stakeholders Meeting 

October 5,1999 

SIGN-IN SHEET 

<Please make any necessary corrections and check off attendance, or fill in your name, etc. in a blank row> 

Name 

Norman Morrow 

Jack McClure 

Bob Hermanson 

John Dege 

PaulJann 

Affiliation 

Exxon Chemical 

Americas 

Shell Chemical 

(Americas) 

BP Amoco Group 

Dupont 

Dupont 

Mailing Address 

P.O. Box 3272 

Houston, TX 77253 

P.O. Box 4320 

Houston, TX 77210 

801 Warrenville Rd. 

Mail Code 708IC 

Lisle, IL 60532 

1007 Market Street, 

N2518 

Wilmington, DE 19898 

1007 Market Street, 

(N5448A) 

Wilmington, DE 19898 

Telephone/Fax 

Number 

(281)870-6112 

(281) 588-2522-fax 

(713)241-3999 

(713) 241-2494 - fax 

(630) 434-6245 

(630) 434-6235 - fax 

(302) 773-0900 

(302) 774-1361 - fax 

(302) 774-8043 

e-mail Address 

norman.l. morrow@ 

exxon.com 

jlmcclure@ shellus.com 

hermanrw@bp.com 

john.a.dege@usa.dupont. 

com 

paul.r.jann@usa.dupont.com 

In 

Attendance 

• 

• 

• 

• 

p:\n831\meetings\rndtble\signin2.wpd 
Organic Liquids Distribution (non-Gasoline) MACT 

Stakeholders Meeting 

October 5,1999 

Name 

Tom Hmiel 

Jordan Jacobsen 

Karin Ritter 

Laura Burrell 

John Prokop 

Cliff Harvison 

Del Billings 

(DHM-11) 

Affiliation 

BASF Corporation 

Alyeska Pipeline 

Service Company 

American Petroleum 

Institute 

Chemical 

Manufacturers 

Association 

Independent Liquid 

Terminals 

Association 

National Tank 

Truck Carriers, Inc. 

U.S. Department of 

Transportation 

Mailing Address 

3000 Continental Dr. 

North 

Mt. Olive, NJ 07828 

1835 South Bragaw 

Street 

Anchorage, AK 99512 

1220 L Street, N.W. 

Washington, DC 20005 

1300 Wilson Boulevard 

Arlington, VA 22209 

Suite 650,1133 15th 

Street, N.W. 

Washington, DC 20005 

2200 Mill Road 

Alexandria, VA 22314 

400 Seventh Street, 

S.W. 

Washington, DC 20590 

Telephone/Fax 

Number 

(973) 426-2624 

(973) 426-2622 - fax 

(907) 265-8384 

(907) 265-8586 - fax 

(202) 682-8472 

(202)682-8031-fax 

(703) 741-5246 

(703) 741-6246 - fax 

(202) 659-2301 

(202) 466-4166-fax 

(703) 838-1960 

(703) 684-5753 - fax 

(202) 366-4488 

(202) 366-8700 - fax 

e-mail Address 

hmielt@basf-corp.com 

jacobsenje@ 

alyeska-pipeline.com 

ritterk@api.org 

Laura Burrell@cmahq.com 

ProkopILTA@aol. com 

nttc@juno.com 

delmer.billings@rspa.dot. 

gov 

In 

Attendance 

• 

(phone) 

• 

• 

p:\n819\meetings\mdt_3le _ign__. wpd 
Organic Liquids Distribution (non-Gasoline) MACT 

Stakeholders Meeting 

October 5,1999 

Name 

Don Wang 

Greg LaFlam 

Bernd Haneke 

Martha Smith 

Robert Nolan 

Liane Piatt 

Affiliation 

Union Carbide 

PES 

PES 

U.S. EPA 

Exxon 

Dow Chemical 

Mailing Address 

3200 Kanawha Turnpike 

P.O. Box 8361 

S. Charleston, WV 

25303 

5001 S. Miami Blvd. 

PO Box 12077 

RTP, NC 27709 

5001 S. Miami Blvd. 

PO Box 12077 

RTP, NC 27709 

Mail Drop 13 

RTP, NC 27711 

P.O. Box 2180 

Houston, TX 77252 

2301 N. Brazosport 

Blvd., OC-708 

Freeport, TX 77541-

3257 

Telephone/Fax 

Number 

(304) 747-4924 

(304) 747-3680 - fax 

(919)941-0333 

(919) 941-0234-fax 

(919) 941-0333 

(919) 941-0234-fax 

(919) 541-2421 

(919) 541-0246-fax 

(713) 656-7209 

(713) 656-6594-fax 

(409)238-5418 

(409) 238-4903 - fax 

e-mail Address 

wangdl@ucarb.com 

greg.laflam@pes.com 

bernd.haneke@pes.com 

smith.martha@epa.gov 

rmnolan@exxon.com 

lmplatt@dow.com 

In 

Attendance 

• 

• 

• 

• 

• 

• 

p:\n819\meetings_ndtable\signin2.wpd 
Organic Liquids Distribution (non-Gasoline) MACT 

Stakeholders Meeting 

October 5,1999 

Name 

Joel Fazzio 

Bill Beck 

Denise Michelson 

Bill Ruhl 

Gary Wilson 

Larry Sorrels 

Rick Wright 

Affiliation 

International Matex 

Tank Terminals 

Mobil Corporation 

ARCO 

EMCO Wheaton 

DTM, Inc. 

Marathon Oil Co. 

U.S. EPA 

Ashland Chemical 

Co. 

Mailing Address 

321 St. Charles 

New Orleans, LA 70130 

3225 Gallows Road 

Room6W109 

Fairfax, VA 22039 

333 S. Hope Street 

Los Angeles, CA 90071 

2501 Constant 

Comment Place 

Louisville, KY 40299 

539 S. Main Street 

Findlay, OH 

Mail Drop 15 

RTP, NC 27711 

Telephone/Fax 

Number 

(504)586-8300 

(703) 849-6245 

(703) 849-6295 - fax 

(213)486-0662 

(213) 486-2021-fax 

(419)421-3666 

(419)421-4515-fax 

(919)541-5041 

(614) 790-3577 

(614) 790-6080 - fax 

e-mail Address 

joelfazzio@imtt.com 

bill_r_beck@ 

email.mobil.com 

ztcdcm@is.arco. com 

bruhl@syltone.com 

grwilson@ marathonoil.com 

sorrels, larry @epa. gov 

rlwright@ashland.com 

In 

Attendance 

• 

• 

• 

• 

• 

• 

- . 

p:\n819\meetings\radtable\signin2. wpd 
Organic Liquids Distribution (non-Gasoline) MACT 

Stakeholders Meeting 

October 5,1999 

Name 

Usha Mehra 

David Darling 

Jackie Surles 

Tom Jackson 

Alice Crowe 

Jan Werner 

Affiliation 

GATX Terminals 

Corporation 

National Paint and 

Coatings 

Association 

Louisiana DEQ 

Equiva Services 

LLC 

American Petroleum 

Institute 

Marathon Ashland 

Petroleum 

Mailing Address 

405 Clinton Drive 

P.O. Box 465 

Galena Park, TX 77547 

1500 Rhode Island 

Ave., NW 

Washington, DC 20005 

12700 Northborough 

Drive 

Houston, TX 77067 

1220 L Street, NW 

Washington, DC 20005 

539 S. Main Street . 

Findlay, OH 45840 

Telephone/Fax 

Number 

(713)450-0400 

(713) 450-0450-fax 

(202) 462-6272 

(281)874-7947 

(202) 682-8249 

(419)421-4300 

e-mail Address 

mehrau@gatx.com 

ddarling@paint.org 

j ackie_s@deq. state. la.us 

thj ackson@equi va. com 

crowe@api.org 

JTWerner@MAPLLC.com 

In 

Attendance 

• 

• 

• 

(phone) 

(phone) 

p:\n819\meetings\rndtable\sighin2.wpd 
Organic Liquids Distribution (non-Gasoline) MACT 

Stakeholders Meeting 

October 5,1999 

Name 

David Mazzocco 

Peter Goodier 

Hal Taback 

Kent C. Hustvedt 

Robert Matejka 

Tara Lanier 

Affiliation 

PPG 

Emco Wheaton 

DTM 

Hal Taback Co. 

(HTC) -

Consultant to API 

U.S. EPA 

Akzo Nobel 

Coatings 

Ashland Chemical 

Co. 

Mailing Address 

2501 Constant 

Comment Place 

Louisville, KY 40299 

378 Paseo Sonrisa 

Walnut, CA 91789 

Mail Drop 13 

RTP,NC 27711 

1431 Progress Ave. 

P.O. Box 2124 

High Point, NC 27261 

Telephone/Fax 

Number 

(412)492-5476 

(412) 492-5377-fax 

(502) 266-6677 

(502) 266-6689 - fax 

(909)869-1188 

(909) 869-1190-fax 

(919)541-5395 

(919) 541-0246-fax 

(336)801-0872 

(336) 883-9525 - fax 

(614)790-3577 

(614) 790-6080 - fax 

e-mail Address 

mazzocco@ppg.com 

PGoodier@syltone.com 

taback@ix.netcom.com 

hustvedt.ken@epamail.epa.gov 

bob.c.matejka@akzonobel.com 

In 

Attendance 

• 

(phone) 

• 

• 

• 

• 

<A 

p:\n83 l\meetings\rndtble\signin2.wpd 
P.17 

Memorandum - 4th Roundtable 

October 20, 1999 

Page 10 

Attachment 2 - EPA/ESD Presentation 

 
P.18 

U.S. EPA - ORGANIC LIQUIDS DISTRIBUTION MACT RULE 

4th STAKEHOLDERS MEETING 

EPA Environmental Research Center (ERC Building), Classroom #1 

9:00 

9:00-9:15 

9:15-10:15 

10:15-10:30 

10:30-11:40 

11:40-12:30 

12:30-1:15 

1:15-1:45 

1:45-2:00 

2:00-3:00 

3:00 

Research Triangle Park, North Carolina 

October 5,1999 

© Call-in number: (919) 541-4332 

Agenda Call Meeting to Order 

Introductions U.S. EPA 

Review of Meeting Objectives and Agenda 

EPA Presentation (MACT Floors, U.S. EPA/PES 

Draft Rule Proposal, Impacts) 

Break 

Questions/Discussion All Participants 

Lunch Break 

EPA Presentation (Economic Analysis) U.S. EPA Economics 

Group 

Questions/Discussion All Participants 

Break 

Discussion/Wrap-up All Participants 

Meeting Adjourn 

/7 
P.19 

ORGANIC LIQUIDS DISTRIBUTION 

(OLD) MACT RULE 

DISCUSSION OF MACT FLOORS, 

DRAFT RULE PROPOSAL, 

AND IMPACTS 

OCTOBER 5,1999 

FOURTH STAKEHOLDERS MEETING 

Waste and Chemical Processes Group 

Emission Standards Division 

U.S. Environmental Protection Agency 

Research Triangle Park, NC 

 
P.20 

• 

• 

• 

• 

• 

• 

OVERVIEW 

Analysis from EPA Survey 

• Industry segments responding to survey 

• Model plants 

• Baseline emissions 

MACT Floors 

• Storage tanks 

• Loading racks 

• Container filling 

• Equipment leaks 

Draft Regulatory Requirements 

• Applicability 

Draft Controls 

Rule Impacts 

• Projected controls 

• Emission reductions 

• Control costs 

Next Steps 

3 

/f 
P.21 

ORGANIC LIQUIDS 

DISTRIBUTION INDUSTRY 

< - Plant Site 

organic 

liquids 

OLD Emission 

Sources: 

- tanks 

- equipment 

Manufacturing Facilities 

- SOCMI 

- refineries 

- other industries 

Current 

MACT Coverage 

OLD Emission 

Sources: 

- tanks 

- racks 

- containers 

- equipment 

Collocated OLD Operations 

Plant Site 

Organic liquids 

(same emission 

sources as — 

above) 

Stand-alone terminals 

(own the liquids or for-hire storage) 

Manufacturing liquid users with no 

current MACT coverage 

Crude oil pipeline stations 

Organic liquids 

(same emission 

sources as 

above) 

Independent OLD Operations 

-2-0 
P.22 

ANALYSIS FROM EPA SURVEY 

7-\ 
P.23 

INDUSTRY SEGMENTS RESPONDING 

TO SURVEY 

Industry 

Segment 

Chemical 

industry 

Refineries 

Terminals 

(for-hire) 

Crude oil 

pipeline 

stations 

Petroleum 

terminals 

Others 

Totals 

No. of 

Responses 

118 

56 

32 

24 

10 

7 

247 

%of. 

Responses 

(rounded) 

48 

23 

13 

10 

4 

3 

100 

%of 

Segment 

Represented 

30 

30 

35 

70 

20 

— 

 
MODEL PLANTS 

Model plants are used for calculation of national 

emission reductions and cost impacts 

Model plants summarize the characteristics of 

OLD operations that affect HAP emissions 

Emission sources are described through 

parameter ranges based on data from actual 

facilities 

13 model plants were developed to represent the 

OLD industry 

Memo on model plants was sent out to 

stakeholders on July 28, 1999 

Stakeholder comments on memo are under 

review 

23 
BASELINE EMISSIONS 

P.25 

Baseline: current (1997) total HAP emissions 

from OLD operations nationwide, 

taking existing controls into account 

Industry 

Segment 

Chem. 

industry 

Refineries 

Terminals 

(for-hire) 

Crude 

pipelines 

Petroleum 

terminals 

Totals 

Storage 

Tanks 

38,800 

6,900 

18,000 

450 

1,750 

(55,900 

Nationwide HAP Totals (tons/yr) 

Loading 

Racks 

4,700 

2,100 

2,900 

0 

300 

10,000 

Container Equipment 

Filling Leaks 

47 10,050 

•1 1,450 

1 5,000 

0 50 

1 950 

50 17,500 

Totals 

53,600 

10,500 

25,900 

500 

3,000 

93,500 

Values may change as the result of ongoing 

reanalyses 

8 

2± 
P.26 

MACT FLOORS 

ZS" 
P.27 

MACT FLOORS 

STORAGE TANKS 

Liquids and tank sizes reported in survey that were 

below the requested cutoffs (minimum 1,000 ppmw 

HAP, 0.1 psia, 5,000 gal. capacity) were not considered 

in the data analysis 

Large tanks storing surveyed liquids are controlled using 

control devices or well-sealed floating roofs 

MACT floors satisfy HON levels of control (well-sealed 

floating roof, control device, or equivalent) for these 

tank size/vapor pressure combinations: 

Tanks at Existing Sources Tanks at New Sources 

1. 20,000-40,000 gal. & 1.10,000-40,000 gal. & 

> 1.9 psia > 1.9 psia 

2. ..40,000 gal. & 2. > 40,000 gal. & 

>0.75 psia >0.1 psia 

10 

  
P.28 

MACT FLOORS 

CARGO TANK LOADING RACKS 

Many loading racks (-40%) transferring surveyed 

liquids are controlled using a control device (flare, 

enclosed combustion, carbon adsorption, etc.) 

MACT Floor (existing and new sources): 

Control organic liquid loading racks at 95 

percent efficiency, or to 20 ppmv exhaust 

concentration for enclosed combustion devices 

• Restrict loadings to vapor-tight cargo tanks 

11 

2.1 
P.29 

MACT FLOORS 

CONTAINER FILLING 

Control devices are in use at about 25% of large 

container filling operations 

MACT floor for large containers (55 gallon 

drums or larger) at existing and new sources is 

the use of controlled transfers 

MACT floor for containers smaller than 55 

gallons is "no control" 

12 

7 2 
P.30 

MACT FLOORS 

EQUIPMENT LEAKS 

Approximately 35 percent of responding 

facilities have a formal leak detection and repair 

program (instrument LDAR) 

MACT floor for existing and new sources: 

• Instrument LDAR program similar to 

existing Federal programs 

The EPA has requested data from stakeholders 

on results of existing LDAR programs at OLD 

facilities in order to evaluate their effectiveness 

13 

ZPt 
P.31 

DRAFT REGULATORY 

REQUIREMENTS 

14 

 
DRAFT REGULATORY 

REQUIREMENTS 

APPLICABILITY 

Rule applies to existing, new, and reconstructed OLD 

operations 

Principal types of OLD operations: 

• Dedicated liquid terminal facilities (for-hire and/or 

proprietary) 

• Operations collocated with SOCMI facilities, 

refineries, other manufacturing plant sites 

• Crude oil pipeline pumping/breakout stations 

Major sources only (determination must be done for 

entire plant site) 

Applies to liquids with 5% by weight or more of the 

organic HAP listed in the OLD HAP table 

Excludes gasoline, Avgas, and fuels consumed or 

dispensed on the plant site 

No duplicate coverage for emission sources already 

covered by another Title III MACT standard 

15 

SI 
P.33 

DRAFT REGULATORY 

REQUIREMENTS 

TABLE OF ORGANIC HAP FOR OLD 

NESHAP 

Only the HAP listed in this table will be 

covered by the OLD MACT standard 

This table was created by combining HAP 

reported in the OLD data base and Table 2 of 40 

CFR 63, subpart G of the HON 

This table only includes organic HAP with 

vapor pressures >0.1 psia at 25 degrees C 

(approx. 77 degrees F) 

Includes 65 organic HAP compounds, and 

excludes 55 organic HAP compounds 

16 

^ ^ 
P.34 

DRAFT REGULATORY 

REQUIREMENTS 

Organic HAP for OLD NESHAP 

Compound name 

l,4Dioxane 

1,3 Dichloropropene 

1,1,2 Trichloroethane 

1,2 Epoxypropane (propyleneoxide) 

2 Butanone (methyl ethyl ketone, MEK) 

Acetaldehyde 

Acetamide 

Acetonitrile 

Acrylic Acid 

Acrylonitrile 

Allyl Chloride (3 chloropentene) 

Benzene 

Bis(Chloromethyl)Ether 

Bromoform (tribromomethane) 

Bromomethane 

Butadiene-(1,3) 

Carbon Disulfide 

Carbon Tetrachloride 

Chlorobenzene 

Chloroethane (ethyl chloride) 

Chloroform 

Chloromethane (methylchloride) 

Chloroprene 

Cumene (isopropylbenzene) 

CAS 

Number 

123-91-1 

542-75-6 

79-00-5 

75-56-9 

78-93-3 

75-07-0 

60-35-5 

75-05-8 

79-10-7 

107-13-1 

107-05-1 

71-43-2 

542-88-1 

75-25-2 

74-83-9 

106-99-0 

75-15-0 

56-23-5 

108-90-7 

75-00-3 

67-66-3 

74-87-3 

126-99-8 

98-82-8 

17 

S3 
P.35 

DRAFT REGULATORY 

REQUIREMENTS 

Organic HAP for OLD NESHAP 

Compound name 

Dichloroethane (1,2) (ethylene 

dichloride) 

Dichloroethane (1,1) 

ethylidenedichloride 

Dichloroethyl Ether 

Dichloropropane 1,2 

Dimethyl Hydrazine (1,1) 

Epichlorohydrin 

Epoxybutane 1,2 

Ethenylbenzene (styrene) 

Ethyl Acrylate 

Ethylbenzene 

Ethylene Dibromide 

Ethylene Oxide 

Formaldehyde 

Glycol Ethers 

Hexane (-n) 

Hydrazine 

Methanol 

Methyl Isocyanate 

Methyl Hydrazine 

Methyl Methacrylate 

Methyl Tert-Butyl Ether 

Methyl Isobutyl Ketone 

Methylene Chloride (dichloromethane) 

CAS 

Number 

107-06-2 

75-34-3 

111-44-4 

78-87-5 

57-14-7 

106-89-8 

106-88-7 

100-42-5 

140-88-5 

100-41-4 

106-93-4 

75-21-8 

50-00-0 

Various 

110-54-3 

302-01-2 

67-56-1 

624-83-9 

60-34-4 

80-62-6 

1634-04-4 

108-10-1 

75-09-2 

18 

3L 
P.36 

• 

DRAFT REGULATORY 

REQUIREMENTS 

Organic HAP for OLD NESHAP 

Compound name 

Nitropropane 2 

Phosgene (decomposes) 

Propanal (propionaldehyde) 

Propenal (acrolein) 

Tetrachloroethane (1,1,2,2) 

Tetrachloroethene 

Toluene 

Trichloroethane 1,1,1 methyl chloroform 

Trichloroethylene 

Triethylamine 

Trimethylpentane 2,2,4 

Vinyl Acetate 

Vinyl Chloride 

Vinylidene Chloride (see 

1,1 dichloroethene) 

Xylene (-p) 

Xylene (-o) 

Xylene (-m) 

Xylenes (Isomers and Mixtures) 

CAS 

Number 

79-46-9 

75-44-5 

123-38-6 

107-02-8 

79-34-5 

127-18-4 

108-88-3 

71-55-6 

79-01-6 

121-44-8 

540-84-1 

108-05-4 

75-01-4 

75-35-4 

106-67-9 

95-47-6 

108-38-3 

1330-20-7 

19 

sir 
DRAFT REGULATORY 

REQUIREMENTS 

DRAFT CONTROLS 

Emission Source Standards for Existing and 

New Sources 

Storage tanks 

1. Existing sources: 

20k-40k gal & >1.9 psia; >40k 

gal & >0.75 psia 

2. New sources: 10k-40k gal & 

> 1.9 psia; >40kgal& >0.1 psia 

Floating roof with required rim 

seals and fittings controls, control 

device for fixed-roof tanks, or 

equivalent controls (similar to 

HON) 

Container filling (55 gal. 

or larger)* 

Good engineering and safety 

practices from National Emission 

Standards for Containers, 40 CFR 

63, subpart PP [61 FR 34186, 7-1-

96]: submerged fill, vapor 

balance, vapor recovery, etc. 

Loading racks (cargo tanks)* 95 percent control (or 20 ppmv for 

combustion devices), plus annual 

cargo tank vapor tightness test 

Equipment leaks Leak detection and repair (LDAR) 

program similar to HON program 

or to other LDAR programs under 

40 CFR 60, 61, or 63 

* Would apply to organic liquids containing at least 5 percent by weight of the HAP in 

the OLD HAP table. In addition, volume-weighted vapor pressure cutoffs (for example, 

0.5 psia for total liquid) and liquid throughput cutoffs are being investigated that would 

exempt low-emitting liquids and transfer operations with very small volumes of activity. 

20 

2>(o 
P.38 

RULE IMPACTS 

21 

_7 
RULE IMPACTS 

PROJECTED O.L.D. CONTROLS 

Approx. 475 facilities are expected to institute an 

instrument LDAR program for OLD equipment 

Many of these facilities would also need to install 

additional controls: 

1,200 new floating roofs installed in fixedroof tanks at 150+ facilities 

• 410 rim seal upgrades to existing floating 

roofs at 90+ facilities 

• Control device installed to control loading 

racks at up to 90 facilities 

• Number of facilities that would need to 

modify their filling practices for large 

containers is presently unknown 

22 

.3^ 
RULE IMPACTS 

EMISSION REDUCTIONS 

Emission 

Source 

Storage tanks 

Loading racks 

Containers 

Equipment 

Totals 

HAP Emissions (tons/yr) 

Baseline 

65,900 

10,000 

50 

17,500 

93,400 

After Rule 

52,200 

700 

5 

9,400 

62,300 

Reduction 

13,700(21%) 

9,300 (93%) 

45 (90%) 

8,100(46%) 

31,100 (33%) 

23 

2><7 
P.41 

RULE IMPACTS 

CONTROL COSTS 

Emission Source Controlled 

Add control devices to fixed-roof 

tanks 

Upgrade floating roof tanks 

Add control devices to loading 

racks 

Maintain vapor-tight cargo tanks 

Add control practices for large 

container filling 

Perform LDAR programs 

Total 

Nationwide Annual Cost 

$2.8 million/yr 

$1.5 million/yr 

$6.6 million/yr 

<to be determined> 

<to be determined> 

$59.5 million/yr 

$70.4+ million/yr 

24 

 
P.42 

NEXT STEPS 

Consider stakeholder comments in completing 

analyses and rule proposal 

Internal EPA and OMB reviews of draft rule and 

support materials 

Rule proposal in August 2000 

Rule promulgation in October 2001 

25 

Hi 
P.43 

Memorandum - 4th Roundtable 

October 20, 1999 

Page 11 

Attachment 3 - EPA/ISEG Presentation 

 
P.44 

Economic and Small Entity Analysis 

Information 

for 

Organic Liquid Distribution NESHAP 

Stakeholders 

\8SU) 

Prepared by 

Office of Air Quality Planning and Standards 

Innovative Strategies and Economics Group 

September 20,1999 

^3 
P.45 

Larry Sorrels 

(919) 541-5041 

(919) 541-0839 fax 

sorrels.larry@epa.gov 

For additional information on economic analyses at OAQPS, including guidelines for 

conducting economic impact analyses and downloads of completed NESHAP (MACT) 

economic impact studies, visit the Economic and Cost Analysis Support page at 

vrww.epa.gov/ttn/ecas 

J£. 
P.46 

Background 

What are economic analyses? 

*• Analyses of economic impacts (market and financial) and economic benefits (health and welfare) 

• In this context, analyses of regulatory costs (facility and national) are not economic analyses 

Why conduct economic analyses? 

• Fulfill statutory requirements and requirements of Presidential Directives (see Table 1 and Figure 

1) 

• Provide infonnation to the regulatory team that is useful in deciding the level, form, or 

construction (e.g., subcategorization) of standards 

What do we try to estimate in an economic analysis? 

Benefit-Cost Analyses 

• Social benefits: quantity and monetary value of health and welfare benefits (e.g., value of avoided 

cancer incidences) for all populations and select subpopulations (e.g., children minority 

populations, low-income populations). Note: benefits analyses are normally only conducted for 

major rules (e.g. total annual nationwide costs > $100 million) 

• Social costs, if significantly different from engineering costs (e.g., cost associated with a product 

ban) 

Economic Impact Analyses 

• Magnitude of price and quantity changes in affected product markets 

• Changes in industry structure 

• Potential employment effects 

• Differential impacts on specific subgroups: small entities (for SBREFA purposes), government 

entities, minority populations, low-income populations 

• Potential international trade impacts 

• Changes in industry and company financial health 

What information is needed to conduct economic analyses? (see Figure 2) 

Benefit-Cost Analyses 

*• Characteristics of affected human and other populations 

• Willingness to pay (or proxy) for health and welfare improvements (and disbenefits) 

Economic Impact Analyses 

• Incremental fixed and variable control costs for regulatory alternatives (actual plants or readily 

mapped model plants). Incremental refers to costs above baseline conditions. 

• Supply and demand characteristics of affected product markets 

• Representative financial data on affected companies 

•• Identity and characteristics of small entities and affected government entities 

-1-

tyr 
Table 1: Statutes and Executive Orders Requiring Economic Analyses 

* 

Benefit-Cost Analysis Impact Analysis 

Statutes Periodic assess'ment of 

costs and benefits of the 

CAA (CAA §312) 

Executive Orders E.0.12866: Regulatory 

Planning and Review 

Economic impact assessment of specific 

standards and regulations under the CAA 

(CAA §317) 

Employment impacts (CAA §321(a)) 

Small community impacts (CAA §810) 

Foreign trade impacts (CAA §811(b)) 

Regulatory Flexibility Act (RFA) 

Small Business Regulatory Enforcement 

Fairness Act (SBREFA) 

Unfunded Mandates Reform Act (UMRA) 

Paperwork Reduction Act (PRA) 

E.0.12866: Regulatory Planning and 

Review 

E.0.12875: Enhancing the 

Intergovernmental Partnership 

E.0.12898: Federal Actions to Address 

Environmental Justice in Minority 

Populations and Low-Income Populations 

E.0.13045: Protection of Children from 

Environmental Health Risks and Safety 

Risks 

-2-

___ • 
P.48 

-T 

Figure 1: Economic Analysis Drivers Impact Analysis Drivers 

Sequence of Questions for Determining the Necessary Impact Analyses 

Decision to Regulate 

V 

Preliminary Screening Assessment 

V 

| E.0.12866: Is the Rulemaking a Significant Regulatory Action? 

YES 

r 

Benefit-Cost Analysis 

> 

NO 

Economic Impact Assessment 

i 

•\r V 

E.O. 12875 — UMRA: Does Regulatory Action have significant impact on 

State, local, or tribal governments? 

YES 

1 

| 

' 

Analysis of impacts on State, 

local, and tribal governments 

> ' 

' 

NO 

Statement of no impact 

v 

RFA & SBREFA: Does Regulatory Action have major impact on sm 

YES ' 

Regulatory Flexibility Analysis 

' ' 

all entities? 

NO 

Certify no significant impact 

> 

PRA & 5 CFR 1320: Does Regulatory Action result in reportii 

recordkeeping requirements? 

YES | 

' 

Information Collection Request 

> ' > 

E.O. 13045: Does Regulatory Action impact the health or safety of i 

YES | 

> 

Analysis of impacts on 

children's health 

^^^^^^^J ' ^ 

' 

igor 

! 

' 

hildren? ! 

' 

E.O. 12898: Does Regulatory Action impact low-income or minority populations? 

YES 

> 

Analysis of Equity Impacts 

' 

: 

' 

Analysis Specifications 

HI 
P.49 

Figure 2: Flow of Analytical Information in Regulatory Development 

Data Collection 

population data 

emissions data 

control devices 

equipment characteristics 

Engineering Analysis 

model facilities 

• regulatory options 

Industry 

Profile 

Demographic 

Data 

Location Emissions 

Reductions 

Costs 

1 

Market 

Information 

Small Business 

Characteristics 

Air Quality Modeling 

and Risk Analysis 

Health and 

Environmental 

Effects 

"Economic Impact Analysis" 

market adjustments 

welfare effects 

financial analysis 

"impact" analysis 

(SBREFA, UMRA, etc) 

1 

Benefits Analysis 

Emissions 

Changes 

< ' 

Social 

Benefits 

"Economic Analysis" 

(major rules) 

Social 

Costs 

Distributional 

Effects 

Economic Information 

Used in Regulatory 

Decision Making 

-4-

£ 
P.50 

Information on EPA Small Entity Analyses 

What are small entity analyses? 

• Small entity analyses provide estimates of impacts to small entities (i.e., businesses, nonprofit 

firms, and communities or governments) from implementation of a regulation. 

The impacts estimated include the following: 

* Number of small businesses, nonprofit firms, and communities or governments 

potentially affected, and the proportion of small businesses affected in an industry 

facing implementation of a rule 

* Costs of compliance as a percentage of sales or revenues for affected small entities. 

This comparison of compliance costs to sales is called a screening analysis. 

• Small entity analyses are NOT cost analyses. Small entity analyses use costs of compliance as 

an input. 

• Small entity analyses are a subset of the economic impact analyses the EPA conducts for each 

rule that will be implemented. Economic impact analyses provide estimates of impacts to all 

entities affected by implementation of a rule, not just the small entities. 

Why conduct small entity analyses? 

• Fulfill legal requirements. Small entity analyses are required by the Small Business Regulatory 

Enforcement Fairness Act (SBREFA). SBREFA is an amendment to the Regulatory Flexibility 

Act (RFA), an Act signed in 1980 requiring Federal agencies to" conduct analyses of impacts to 

small entities from compliance with their rules. Small entity analyses are known as Regulatory 

Flexibility Analyses because they were first required by this Act. In addition, the EPA is 

required to estimate impacts to small communities under Section 810 of the Clean Air Act. 

Provide information to the rulemakers that is useful in deciding the level, form, or design of 

standards. Small entity analyses can be particularly useful in deciding to subcategorize a 

standard (that is, control a certain type of sources in an affected industry differently than the 

rest). 

-5-

HI