Date:
September
5,
2002
From:
Brenda
Shine,
North
State
Engineering,
Inc.

To:
David
Randall
RTI
Project
Leader
Miscellaneous
Organic
Chemicals
MACT
Standard
Subject:
Meeting
Minutes
American
Chemical
Council
Meeting
August
20,
2002
I.
Purpose
The
meeting
was
requested
by
the
American
Chemistry
Council
(
ACC)
to
discuss
ACC
comments
on
the
proposed
Miscellaneous
Organic
Chemical
Manufacturing
NESHAP.

II.
Place
and
Date
U.
S.
Environmental
Protection
Agency
Office
of
Air
Quality
Planning
and
Standards
Research
Triangle
Park,
North
Carolina
August
20,
2002
III.
Attendees:

Industry
Representatives
Rasma
Zvaners,
ACC
Mike
Vancil,
Bayer
Kathy
Dahl,
Dow
Chemical
John
Dege,
DuPont
Norman
Morrow,
Exxon
Deb
Chapin,
Kodak
Doug
Fitts,
Lyondell
Carolyn
Wacker,
3M
(
via
telephone)
Ron
Shipley,
ACC
(
via
telephone)
Rich
Raiders,
Atofina
Chemicals
(
via
telephone)
Tony
Germinario,
BASF
(
via
telephone)
2
BC
Darji,
BP
(
via
telephone)
Dot
Kelly,
Ciba
Specialty
Chemicals
Consultant
(
via
telephone)
Paul
Jann,
Dupont
(
via
telephone)
Steve
Gossett,
Eastman
(
via
telephone)
Jamie
Leonard,
ISP
(
via
telephone)
Ed
Moody,
Stepan
Company
(
via
telephone)

USEPA
Randy
McDonald
RTI
International
David
Randall
North
State
Engineering
Brenda
Shine
IV.
Introduction
On
August
20,
2002,
representatives
of
the
American
Chemical
Council
met
with
EPA
and
contractors
to
discuss
provisions
in
the
proposed
Miscellaneous
Organic
Chemicals
NESHAP
(
MON).
Attached
to
this
memoranda
are
a
meeting
agenda
and
other
information
developed
by
ACC,
and
information
developed
by
EPA.

The
following
general
issues
were
discussed,
as
indicated
in
the
ACC
Meeting
agenda
(
see
Attachment
A):
1)
Applicability,
2)
Emission
Limitations,
3)
Compliance
Dates,
and
4)
Miscellaneous
Issues.

The
paragraphs
below
summarize
the
discussion.

V.
Discussion
A.
Applicability
The
ACC
put
together
logic
diagrams
for
applicability
 
these
diagrams
are
the
same
diagrams
contained
in
the
written
comments
(
see
Attachment
B).
Overall
the
commenter's
concerns
are
that
applicability
should
be
clear.
They
believe
this
clarity
comes
from
using
the
NAICS
codes
to
define
processes
that
make
MON
product.
Additionally,
there
should
be
some
consideration
of
deminimis
levels
and
impurities.
They
suggest
looking
at
the
HON
definitions.
They
believe
that
there
should
be
a
separate
floor
and
analysis
for
inorganics
(
HCl)
emissions.
Finally,
they
want
EPA
to
consider
simplifying
the
compliance
strategy
when
there
is
overlap
with
other
standards.
This
situation
would
most
often
occur
when
multipurpose
processing
equipment
is
used.
They
suggest
using
the
primary
product
concept
or
an
opt­
in
concept
and
allowing
compliance
with
either
rule
for
all
processes
that
share
the
equipment.
In
addition
to
these
3
overlapping
MACT
standards
for
non­
dedicated
equipment,
EPA
also
needs
to
consider
overlap
with
the
Organic
Liquid
Distribution
NESHAP
and
Part
60
and
61
rules.

Industry
and
EPA
also
discussed
the
family
of
materials
concept
contained
in
the
proposed
rule.
EPA
had
some
prior
discussions
with
3M
and
summarized
the
additional
concept
being
discussed
related
to
regulating
equipment
that
is
in
multipurpose
use
(
i.
e.,
a
vent­
based
annual
mass
threshold,
regardless
of
process,
above
which
control
is
required).
Several
ACC
representatives
(
Eastman
and
Kodak)
stated
that
they
did
not
report
emissions
information
on
EPA's
proposed
groupings
of
families
of
materials.

B.
Emission
Limitations
The
discussion
focused
on
differences
in
batch
and
continuous
operations.
ACC's
thoughts
regarding
the
separation
of
continuous
and
batch
vents
have
evolved
somewhat
from
the
position
described
in
their
written
comments.
They
now
believe
a
distinction
is
necessary
between
batch
and
continuous
process
vents,
rather
than
processes.
Another
related
issue
is
the
definition
of
storage
tank
and
process
vent.
An
example
concern
is
identical
tanks
in
a
tank
farm
that
would
be
subject
to
different
requirements
only
because
they
serve
different
functions.
ACC
submitted
additional
written
comments
regarding
their
preferred
definitions
for
process
vents,
surge
control
vessels,
and
storage
tanks
(
see
Attachment
C).
EPA
also
then
presented
additional
information
on
a
proposed
solution
to
concerns
raised
by
commenters
(
see
Attachment
D).
Under
this
approach,
tanks
with
capacities
less
than
10,000
gallons
would
be
considered
either
process
vents
or
surge
control
vessels,
depending
on
their
function,
and
any
tank
over
10,000
would
be
considered
a
storage
tank.
Surge
control
vessels
and
bottoms
receivers
would
be
subject
to
the
same
requirements
as
storage
tanks.
The
issues
were
not
resolved
during
the
meeting,
but
warrant
additional
review
by
both
industry
and
EPA.

Additional
concepts
discussed
were
whether
the
rule
should
contain
an
allowance
to
route
emission
streams
to
fuel
gas
systems,
using
language
like
in
the
ethylene
MACT
to
specify
compliance
requirements
as
in
subpart
SS
for
continuous
process
vents,
exemptions
for
venting
from
opening
of
equipment
for
health
and
safety
and
for
exemptions
from
equipment
leak
monitoring
for
components
in
high
pressure
systems
which
industry
believes
is
a
safety
issue
(
an
example
identified
was
polyethylene).

Another
issue
discussed
was
how
to
deal
with
aggregated
vent
streams.
The
ACC
representatives
favor
the
approach
in
subpart
SS
or
subpart
JJJ.
The
procedures
in
subpart
JJJ
were
discussed,
as
was
a
potential
variation
offered
by
EPA
(
see
Attachment
E).

C.
Compliance
Dates
Issues
discussed
included
an
"
opt­
in"
early
(
prior
to
the
compliance
date
of
the
standards)
to
some
of
the
standards
 
for
example,
the
Subpart
UU
equipment
leaks
programs
for
all
processes
at
a
facility.
Although
the
facilities
could
comply
with
UU
for
selected
processes
that
4
are
covered
by
sources
with
applicability
to
the
CAR,
this
takes
a
Title
V
permit
change.
Industry
was
unclear
as
to
whether
an
opt­
in
would
trigger
the
same
Title
V
revision
process.

The
ACC
representatives
reiterated
their
concern
that
requiring
submittal
of
the
notification
of
compliance
status
report
on
the
compliance
date
rather
than
150
days
after
the
compliance
date
does
not
allow
enough
time
to
meet
all
of
the
compliance
requirements,
and
it
is
inconsistent
with
the
General
Provisions
and
other
rules.
They
also
asked
about
the
provision
in
other
rules
that
allows
up
to
10
years
to
comply
with
the
seal
requirements
for
storage
tanks
equipped
with
internal
or
external
floating
roofs.
This
issue
was
resolved
by
pointing
out
that
Table
4
of
proposed
subpart
FFFF
references
§
63.1063(
a)
of
subpart
WW,
which
contains
the
requested
language.

D.
Miscellaneous
Issues
Miscellaneous
items
include
whether
a
policy
decision
was
made
regarding
removal
of
specific
QA/
QC
provisions
in
favor
of
QA/
QC
in
the
general
provisions,
whether
the
MACT
floors
that
the
MON
proposal
was
based
on
were
valid
and
whether
EPA
was
inclined
to
revise
some
of
their
technical
analyses.
EPA
questionned
ACC's
comments
related
to
the
equipment
leaks
MACT
floor
­­
the
written
comments
do
not
match
EPA's
database.
EPA
is
also
reviewing
the
wastewater
MACT
floor
analysis
and
will
develop
a
separate
floor
for
methanol
and
solubles.
The
minimum
applicability
concentration
appears
to
be
30,000
ppmw
based
on
these
analyses.
The
remaining
floors
probably
will
not
be
revised.

VI.
Action
Items
A.
ACC
Members
1.
Provide
examples
of
large
vessels
that
have
floating
roofs
subject
to
subpart
Kb
and
are
receiving
material
from
batch
reactors.

2.
Provide
information
on
batch
and/
or
continuous
characteristics
of
dryers.

3.
Reexamine
ACC
comments
on
LDAR
programs
assigned
to
processes
in
the
EPA
database
(
see
comments
on
pages
68­
70
of
the
ACC
comments).

B.
EPA
1.
Look
into
the
option
of
allowing
facilities
to
opt­
in
to
the
LDAR
requirements
of
subpart
UU
before
the
compliance
date.

2.
Develop
MACT
floor
for
HCl
emissions
from
process
vents.

3.
Continue
to
develop
the
"
family
of
materials"
concept.
5
4.
Continue
to
examine
options
for
process
vents
and
storage
tanks.
Attachment
A
Agenda
Attachment
B
Logic
Flow
Diagrams
These
four
diagrams
are
contained
in
docket
A­
96­
04,
docket
item
IV­
D­
123.
Attachment
C
Definitions
and
Provisions
Suggested
by
ACC
Attachment
D
EPA
Options
for
Storage
Tanks
and
Process
Vents
Attachment
E
Options
for
Aggregated
Vent
Streams
