MEMORANDUM
Date:
June
30,
2003
Subject:
Summary
of
the
June
3,
2003
Meeting
Between
the
EPA
and
the
Chlorine
Institute
to
Discuss
Issues
Associated
with
the
Mercury
Cell
Chlor­
Alkali
Plant
NESHAP
From:
Heather
P.
Brown,
EC/
R
Phil
Norwood,
EC/
R
To:
Iliam
Rosario,
EPA/
OAQPS/
ESD/
MG
The
purpose
of
this
memorandum
is
to
summarize
the
Environmental
Protection
Agency's
(
EPA)
meeting
on
June
3,
2003,
with
representatives
of
the
Chlorine
Institute
(
CI)
and
companies
that
own
or
operate
mercury
cell
chlor­
alkali
plants.
The
meeting
was
held
by
teleconference.
The
purpose
of
the
meeting
was
to
obtain
additional
clarification
of
comments
submitted
by
CI
and
to
discuss
any
additional
data
needed
by
EPA
to
make
final
decisions.
The
handout
distributed
by
EPA
is
included
as
Attachment
1.

DATE
AND
LOCATION
June
3,
2003
4:
00
p.
m.
­
6:
00
p.
m.

U.
S.
Environmental
Protection
Agency
Research
Triangle
Park,
NC
Held
via
teleconference.

ATTENDEES
The
conference
call
was
attended
by
EPA
representatives,
EPA's
contractor
(
EC/
R
Incorporated),
and
members
of
the
Chlorine
Institute.
The
individuals
who
participated
in
the
meeting
as
well
as
their
affiliations,
are
listed
below.

Environmental
Protection
Agency
Steve
Fruh,
Metals
Group
Iliam
Rosario,
Metals
Group
2
EC/
R
Incorporated
Heather
Brown
Phil
Norwood
Chlorine
Institute
ASHTA
John
Reese
Chlorine
Institute
Art
Dungan
Occidental
Chemical
Dick
Timmons
Olin
Sandy
Moore
Bill
Rankin
Pioneer
Gary
Sellars
Regina
Wilson
PPG
Jerry
Osheka
Terry
Smith
Vulcan
Steve
Hieger
Dawn
Jensen
Chris
Martin
SUMMARY
OF
DISCUSSION
The
following
provides
a
summary
of
the
discussion.
This
summary
is
organized
by
topic
and
does
not
always
represent
the
chronology
of
the
discussion.

Background
On
July
3,
2002,
EPA
proposed
national
emissions
standards
for
hazardous
air
pollutants
from
mercury
cell
chlor­
alkali
facilities
(
67
FR
44672)
under
the
authority
of
section
112(
c)(
6)
and
112(
d).
Eight
comment
letters
were
received
regarding
the
proposed
NESHAP.
During
the
conference
call,
the
comments
received
were
discussed
along
with
EPA's
preliminary
decisions.
The
purpose
of
the
call
was
to
obtain
additional
clarification
of
comments
submitted
by
CI
and
to
discuss
any
additional
data
EPA
would
need
to
make
final
decisions.
3
Issues
In
order
to
clarify
comments
received
and
to
identify
data
potentially
needed
to
make
final
decisions,
EPA
discussed
their
preliminary
decisions
on
the
final
rule
(
Attachment
1).
The
following
were
the
major
points
from
this
discussion.

!
Industry
was
concerned
that
the
nine
operating
facilities
would
not
be
able
to
meet
the
limits.
According
to
industry
personnel,
the
data
used
to
derive
the
limits
were
collected
using
non­
isokinetic
sampling
.
EPA
requested
data
from
the
facility
with
the
best
controlled
emissions
(
i.
e.,
lowest
annual
emissions).

!
Industry
was
concerned
that
they
would
not
have
the
analytical
resources
to
conduct
periodic
testing
on
a
daily
basis.
At
one
facility,
they
only
have
the
ability
to
perform
inhouse
laboratory
analyses
five
days
per
week.
Furthermore,
a
typical
test
takes
several
hours,
including
setup
(
at
least
2
hours),
the
test
itself
(
at
least
2
hours),
and
the
analysis
(
several
hours).

!
Industry
was
concerned
about
sampling
during
off­
shifts
(
e.
g.,
weekends
and
holidays)
if
daily
sampling
was
required.

!
Industry
indicated
that
no
one
could
meet
the
proposed
rule
without
using
a
carbon
adsorption
system.

!
Industry
requested
that
EPA
provide
flexibility
for
demonstrating
compliance
by
allowing
redundant
control
devices.
One
facility
described
their
control
device
system,
which
consists
of
multiple
carbon
beds
in
series.
The
facility
performs
tests
once
per
week
after
each
bed
and
when
the
first
bed
exhibits
breakthrough,
the
carbon
is
changed
out.
The
change­
out
takes
between
36
and
48
hours.
The
facility
suggested
that
when
the
carbon
is
being
changed
out,
they
could
test
the
second
device
on
a
daily
basis.
Under
this
scenario,
compliance
would
be
demonstrated
at
the
outlet
of
the
second
(
or
last)
carbon
bed.

Action
Items
EPA
agreed
to
follow
up
with
the
currently­
operating
facility
that
had
the
lowest
emissions
to
discuss
how
their
emissions
data
were
collected
and
how
annual
emissions
were
calculated
from
the
test
data.
ATTACHMENT
1
Preliminary
Decisions
on
Final
Rule
*
Note:
These
are
draft
decisions.
Final
decisions
are
pending
discussions
with
EPA
work
group
and
management.

1
Mercury
Cell
Chlor­
Alkali
MACT
Preliminary
Decisions
on
Final
Rule
DRAFT
­
June
1,
2003
Comment/
Issue
Preliminary
Decision/
Action*

Issues
Raised
in
Chlorine
Institute
Comments
Title
V
permits
should
not
be
required
(
§
63.8182)
Title
V
permits
will
be
required
for
all
sources
subject
to
the
rule
Compliance
date
should
be
three
years
after
promulgation
(
§
63.8186)
Compliance
date
will
be
moved
to
3
years
from
the
date
the
final
rule
appears
in
the
Federal
Register
Emission
limits
should
be
modified
(
§
63.8190)

Emission
limits
should
not
be
set
"
beyond
the
floor"
While
the
emission
limitation
in
the
final
rule
will
still
be
"
beyond
the
floor,"
it
will
not
be
based
on
the
former
chloralkali
facility
in
Maine.

Emission
limits
should
include
a
factor
for
variability
The
hydrogen/
end­
box
emission
limitation
in
the
final
rule
has
been
changed
to
a
365
day
rolling
average.
Data
will
need
to
be
collected
starting
on
the
compliance
date
and
the
first
compliance
will
be
reported
one
year
(
365
days)
from
the
compliance
date.
Compliance
will
then
be
determined
daily
for
the
previous
365
days.

The
emission
limitation
for
mercury
thermal
recovery
unit
vents
was
not
changed.

Annual
chlorine
capacity
should
be
defined
The
hydrogen/
end­
box
emission
limitation
in
final
rule
will
be
based
on
actual
chlorine
production.
Mercury
Cell
Chlor­
Alkali
MACT
Preliminary
Decisions
on
Final
Rule
DRAFT
­
June
1,
2003
Comment/
Issue
Preliminary
Decision/
Action*

*
Note:
These
are
draft
decisions.
Final
decisions
are
pending
discussions
with
EPA
work
group
and
management.

2
Emission
limits
should
be
modified
(
§
63.8190)

Emission
limits
should
not
depend
on
compliance
test
performance
Initial
compliance
(
§
63.8236)

Continuous
monitoring
system
provisions
should
be
modified
(
§
63.8240
and
§
63.8242)

Demonstration
of
continuous
compliance
(
§
63.8246)

Submissions
(
§
63.8254)
The
operating
limit
concept
in
the
proposed
rule
will
be
removed.
The
final
rule
will
allow
two
options
for
complying
the
hydrogen/
end­
box
and
mercury
thermal
recovery
unit
vent
emission
limitations:

Option
(
1)
Continuously
monitor
the
mercury
concentration
in
each
vent
and
directly
compare
with
the
emission
limitation.

S
For
hydrogen/
end­
box
streams,
other
parameters
(
flow
rate,
etc.)
would
also
need
to
be
continuously
monitored
to
allow
the
calculation
of
the
mass
of
mercury
emissions.
The
emissions
for
the
previous
365
days
would
be
divided
by
the
chlorine
production
for
the
same
period
and
compared
with
the
emission
limitation.

S
For
mercury
thermal
recovery
unit
vents,
a
daily
average
mercury
concentration
would
be
calculated
and
compared
to
the
emission
limitation.

For
this
option,
the
monitoring
system
will
need
to
be
certified
by
comparing
results
with
Method
101/
101A/
102
during
the
initial
and
subsequent
performance
testing.
A
site­
specific
monitoring
plan
will
also
need
to
be
developed
and
followed.
Mercury
Cell
Chlor­
Alkali
MACT
Preliminary
Decisions
on
Final
Rule
DRAFT
­
June
1,
2003
Comment/
Issue
Preliminary
Decision/
Action*

*
Note:
These
are
draft
decisions.
Final
decisions
are
pending
discussions
with
EPA
work
group
and
management.

3
Emission
limits
should
be
modified
(
§
63.8190)

Emission
limits
should
not
depend
on
compliance
test
performance
Initial
compliance
(
§
63.8236)

Continuous
monitoring
system
provisions
should
be
modified
(
§
63.8240
and
§
63.8242)

Demonstration
of
continuous
compliance
(
§
63.8246)

Submissions
(
§
63.8254)
(
continued)
Option
(
2)
Determine
the
mercury
concentration/
emissions
daily
using
a
modified
test
method.

.
S
For
hydrogen/
end­
box
streams,
the
emissions
for
the
previous
365
days
would
be
divided
by
the
chlorine
production
for
the
same
period
and
compared
with
the
emission
limitation.

S
For
mercury
thermal
recovery
unit
vents,
the
measured
mercury
concentration
would
be
compared
to
the
emission
limitation.

For
this
option,
the
modified
method
would
have
to
be
certified
by
comparing
results
with
Method
101/
101A/
102
during
the
initial
and
subsequent
performance
testing.
While
at
least
one
measurement
would
be
required
each
day,
obtaining
multiple
measurements
and
using
the
average
of
all
measurements
taken
during
the
day
would
be
allowed.
Mercury
Cell
Chlor­
Alkali
MACT
Preliminary
Decisions
on
Final
Rule
DRAFT
­
June
1,
2003
Comment/
Issue
Preliminary
Decision/
Action*

*
Note:
These
are
draft
decisions.
Final
decisions
are
pending
discussions
with
EPA
work
group
and
management.

4
Work
Practice
Standards
(
§
63.8192)

Tables
1,
2,
and
6
Most
of
the
recommendations
in
the
Chlorine
Institute
comments
will
be
incorporated.

Table
4
This
table
will
be
retained
in
the
final
rule.

Table
5
This
table
will
be
removed
from
the
final
rule.

Cell
room
monitoring
provisions
should
be
modified
(
§
63.8192(
e))
The
final
rule
will
allow
the
option
of
either
complying
with
the
detailed
work
practice
standards
OR
with
a
cell
room
monitoring
program.
The
rule
will,
however,
include
more
detailed
requirements
for
the
cell
room
monitoring
program.

Subsequent
Performance
Tests
(
§
63.8231)
Since
Title
V
permits
will
be
required
for
all
facilities,
these
provisions
will
reference
the
Title
V
permit
as
proposed.

Recertification
of
the
monitoring
system
or
modified
test
method
will
also
be
required
during
these
subsequent
performance
tests.
Mercury
Cell
Chlor­
Alkali
MACT
Preliminary
Decisions
on
Final
Rule
DRAFT
­
June
1,
2003
Comment/
Issue
Preliminary
Decision/
Action*

*
Note:
These
are
draft
decisions.
Final
decisions
are
pending
discussions
with
EPA
work
group
and
management.

5
Test
Methods
and
Equations/
Procedures
(
§
63.8234)
The
final
rule
will
not
contain
the
requirement
that
performance
tests
for
mercury
thermal
recovery
vents
be
conducted
when
mercury­
containing
wastes
are
being
process
that
result
in
the
highest
mercury
concentration
in
the
vent.

The
provisions
related
to
obtaining
a
sample
containing
twice
the
detection
limit
will
not
be
retained
in
the
final
rule.
The
final
rule
will
require
a
minimum
sampling
time
of
at
least
2
hours
and
a
minimum
sampling
volume
of
at
least
1.7
dscm
(
60
dscf).
If
the
results
are
below
the
analytical
laboratory's
detection
limit,
the
required
results
(
for
compliance
purposes)

will
be
reported
using
the
documented
analytical
detection
limit
to
calculate
the
emission
rate
in
the
units
of
the
standard.

Demonstration
of
continuous
compliance
(
§
63.8246)
The
final
rule
will
retain
the
requirement
that
data
must
be
collected
representing
at
least
75
percent
of
the
15
minute
periods
in
the
operating
day.

Start
up,
shutdowns,
and
malfunctions
(
§
63.8254(
c))
The
final
rule
will
retain
the
immediate
reporting
of
start
up,

shutdown,
or
malfunction
events
as
proposed.

Records
(
§
63.8256
and
Table
8)
Changes
will
be
made
in
response
to
comments.

Records
Retention
(
§
63.8258)
The
final
rule
will
retain
the
requirement
regarding
the
retention
of
the
continuous
monitoring
records
as
proposed.
Mercury
Cell
Chlor­
Alkali
MACT
Preliminary
Decisions
on
Final
Rule
DRAFT
­
June
1,
2003
Comment/
Issue
Preliminary
Decision/
Action*

*
Note:
These
are
draft
decisions.
Final
decisions
are
pending
discussions
with
EPA
work
group
and
management.

6
Definitions
(
§
63.8266)
Changes
will
be
made
to
hydrogen
system
definition
in
response
to
comments.
The
definition
of
by­
product
hydrogen
stream
will
not
be
deleted.

Major
Issues
Raised
by
Other
Commenters
MACT
should
be
non­
mercury
cell
production
The
final
rule
will
retain
the
proposed
new
source
requirement
of
zero
mercury
emissions
but
will
not
extend
this
requirement
to
existing
sources.

MACT
for
mercury
recovery
should
be
non­
thermal
recovery
processes
The
final
rule
will
not
prohibit
thermal
mercury
recovery
processes.

The
EPA
created
too
many
small
subcategories.
There
should
not
be
separate
limits
for
plants
with
and
without
end­
box
ventilation
systems
and
for
oven­
type
and
non­
oven
thermal
mercury
recovery
units.
The
final
rule
will
retain
separate
emission
limits
for
these
situations.

The
rule
should
also
contain
emission
limitations
for
other
parts
of
the
plant,
namely
chlorine
purification,
brine
preparation,

caustic,
and
wastewater
treatment
operations.
The
final
rule
will
not
contain
emission
limitations
for
emission
sources
that
were
not
in
the
proposed
rule.

The
approach
for
establishing
the
emission
limitations
for
thermal
recovery
unit
vents
did
not
result
in
limits
that
were
stringent
enough.
The
mercury
thermal
recovery
unit
vent
emission
limitations
from
the
proposed
rule
will
be
retained
in
the
final
rule.
Mercury
Cell
Chlor­
Alkali
MACT
Preliminary
Decisions
on
Final
Rule
DRAFT
­
June
1,
2003
Comment/
Issue
Preliminary
Decision/
Action*

*
Note:
These
are
draft
decisions.
Final
decisions
are
pending
discussions
with
EPA
work
group
and
management.

7
The
rule
should
include
a
numerical
emission
limitations
for
fugitive
emissions
from
the
cell
room
and
other
areas
in
the
plant.
The
final
rule
will
not
include
numerical
emission
limitations
for
fugitive
emission
sources.

The
cell
room
monitoring
program
should
be
strengthened.
A
specific
comment
is
that
plants
should
not
be
allowed
to
establish
their
own
action
level.
The
final
rule
will
include
more
detailed
requirements
for
the
cell
room
monitoring
program.
One
of
these
requirements
will
be
a
procedure
for
how
plants
are
to
establish
their
action
level.

Note:
In
the
final
rule,
the
cell
room
monitoring
program
is
an
alternative
to
the
work
practices,
and
not
a
requirement
for
every
plant.

The
rule
should
require
an
accounting
and
reporting
of
annual
mercury
consumption.
The
final
rule
will
contain
provisions
to
record
and
report
annual
mercury
consumption.
