Notice2021-15321
Notice of Final Approval for an Alternative Means of Emission Limitation
Primary source
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Published
July 19, 2021
Effective
July 19, 2021
Issuing agencies
Environmental Protection Agency
Abstract
This action announces the Environmental Protection Agency (EPA) approval of the request by Rohm and Haas Chemicals LLC, a subsidiary of The Rohm and Haas Chemical Company (Rohm and Haas), under the Clean Air Act (CAA) for an alternative means of emission limitation (AMEL) for the Standards of Performance for Volatile Organic Liquid Storage Vessels. The AMEL applies to a proposed new vinyl acetate bulk storage tank to be used at its chemical plant in Kankakee, Illinois. The EPA received no adverse comments on the request. This approval document specifies the operating conditions and monitoring, recordkeeping, and reporting requirements that this facility must follow to demonstrate compliance with the approved AMEL.
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<title>Federal Register, Volume 86 Issue 135 (Monday, July 19, 2021)</title>
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[Federal Register Volume 86, Number 135 (Monday, July 19, 2021)]
[Notices]
[Pages 38076-38078]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2021-15321]
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ENVIRONMENTAL PROTECTION AGENCY
[EPA-HQ-OAR-2020-0599; FRL-8194-02-OAR]
Notice of Final Approval for an Alternative Means of Emission
Limitation
AGENCY: Environmental Protection Agency (EPA).
ACTION: Notice; final approval.
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SUMMARY: This action announces the Environmental Protection Agency
(EPA) approval of the request by Rohm and Haas Chemicals LLC, a
subsidiary of The Rohm and Haas Chemical Company (Rohm and Haas), under
the Clean Air Act (CAA) for an alternative means of emission limitation
(AMEL) for the Standards of Performance for Volatile Organic Liquid
Storage Vessels. The AMEL applies to a proposed new vinyl acetate bulk
storage tank to be used at its chemical plant in Kankakee, Illinois.
The EPA received no adverse comments on the request. This approval
document specifies the operating conditions and monitoring,
recordkeeping, and reporting requirements that this facility must
follow to demonstrate compliance with the approved AMEL.
DATES: The approval of the AMEL request from Rohm and Haas to operate
its storage tank in Kankakee, Illinois, as specified in this document,
is effective on July 19, 2021.
ADDRESSES: The EPA has established a docket for this action under
Docket ID No. EPA-HQ-OAR-2020-0599. All documents in the docket are
listed on the <a href="https://www.regulations.gov/">https://www.regulations.gov/</a> website. Although listed,
some information is not publicly available, e.g., Confidential Business
Information or other information whose disclosure is restricted by
statute. Certain other material, such as copyrighted material, is not
placed on the internet and will be publicly available only in hard copy
form. Publicly available docket materials are available either
electronically through <a href="https://www.regulations.gov/">https://www.regulations.gov/</a>.
Out of an abundance of caution for members of the public and our
staff, the EPA Docket Center and Reading Room are closed to the public,
with limited exceptions, to reduce the risk of transmitting COVID-19.
Our Docket Center staff will continue to provide remote customer
service via email, phone, and webform. For further information and
updates on EPA Docket Center services, please visit us online at
<a href="https://www.epa.gov/dockets">https://www.epa.gov/dockets</a>. The EPA continues to carefully and
continuously monitor information from the Center for Disease Control,
local area health departments, and our Federal partners so that we can
respond rapidly as conditions change regarding COVID-19.
FOR FURTHER INFORMATION CONTACT: For questions about this final action,
contact Ms. Angie Carey, Sector Policies and Programs Division (E143-
01), Office of Air Quality Planning and Standards, U.S. Environmental
Protection Agency, Research Triangle Park, North Carolina 27711;
telephone number: (919) 541-2187; fax number: (919) 541-0516; and email
address: <a href="/cdn-cgi/l/email-protection#53303221362a7d323d34363f32133623327d343c25"><span class="__cf_email__" data-cfemail="97f4f6e5f2eeb9f6f9f0f2fbf6d7f2e7f6b9f0f8e1">[email protected]</span></a>.
SUPPLEMENTARY INFORMATION: Preamble acronyms and abbreviations. We use
multiple acronyms and terms in this preamble. While this list may not
be exhaustive, to ease the reading of this preamble and for reference
purposes, the EPA defines the following terms and acronyms here:
AMEL alternative means of emission limitation
CAA Clean Air Act
CFR Code of Federal Regulations
EPA Environmental Protection Agency
HAP hazardous air pollutant(s)
NESHAP national emission standards for hazardous air pollutants
NSPS new source performance standards
OAQPS Office of Air Quality Planning and Standards
PRD pressure relief device
PRV pressure relief valve
VAM vinyl acetate monomer
VOC volatile organic compound(s)
Organization of this document. The information in this document is
organized as follows:
I. Background
II. Summary of Public Comments on the AMEL Request
III. AMEL for the Storage Tank
I. Background
On February 8, 2021, the EPA provided public notice and solicited
comment on the request under section 111(h)(3) of the CAA by Rohm and
Haas for an alternative means of emission limitation (AMEL) for the
Standards of Performance for Volatile Organic Liquid Storage Vessels,
40 CFR part 60 subpart Kb, 40 CFR 60.112b, that would apply to a
proposed new vinyl acetate bulk storage tank to be used at its chemical
plant in Kankakee, Illinois (see 86 FR 8618). The volatile organic
compound (VOC) standards at 40 CFR 60.112b were established as work
practice standards pursuant to CAA section 111(h)(1). For standards
established according to that provision, CAA section 111(h)(3) allows
the EPA to permit the use of an AMEL by a source if, after notice and
opportunity for public hearing, it is established to the
Administrator's satisfaction that such AMEL will achieve emissions
reductions at least equivalent to the reductions required under the
applicable CAA section 111(h)(1) standards. NSPS subpart Kb also
includes specific regulatory provisions (i.e., 40 CFR 114b) allowing
sources to request an AMEL for the VOC standards at 40 CFR 60.112b.
In the initial notice, the EPA solicited comment on all aspects of
the AMEL request, including the operating conditions specified in that
document that are necessary to achieve a reduction in emissions of
volatile organic compounds at least equivalent to the reductions
required by 40 CFR 60.112b. Rohm and Haas intends to replace the
existing vinyl acetate monomer (VAM) (CAS 108-05-4) tank (TK-72) with
the proposed bulk storage tank.
Rohm and Haas included in its AMEL application information to
demonstrate that the proposed bulk storage tank, through its vapor
balancing system and
[[Page 38077]]
pressure containment design, will achieve a reduction in emissions at
least equivalent to the reduction in emissions achieved by the VOC
standards at 40 CFR 60.112b. Rohm and Haas's AMEL request was submitted
on June 17, 2020. For Rohm and Haas's AMEL request, including any
supporting materials Rohm and Haas submitted, see Docket ID No. EPA-HQ-
OAR-2020-0599.
This action finalizes our approval of this AMEL request. Section II
summarizes the comments received on the request and our responses
thereto. Section III sets forth the final operating conditions EPA has
established for the proposed bulk storage tank as part of this AMEL
approval.
II. Summary of Public Comments on the AMEL Request
The Agency received comments from only one commenter (Rohm and
Haas) on this action. The comments pertain to the operating conditions
for assuring equivalency that were specified section III of the initial
notice. The comments and our response thereto are summarized below.
A. Comment on Paragraph (3)--EPA Method 21 Monitoring Requirements
Paragraph 3 of the operating conditions in the initial notice
stated that at the Rohm and Haas facility, each of the PRDs and
components of the vapor collection system on the tank must be monitored
on a quarterly basis, using EPA Method 21, and that an instrument
reading of 500 parts-per-million by volume or greater is an excess
emission event.
Rohm and Haas requests that EPA classify an instrument reading of
>=500 ppmv as a leak instead of an excess emission event, thereby
following the National Emission Standards for Organic Hazardous Air
Pollutants (NESHAP) from the Synthetic Organic Chemical Manufacturing
Industry for Process Vents, Storage Vessels, Transfer Operations, and
Wastewater, 40 CFR part 63, subpart G. As mentioned in the initial
notice, in support of its AMEL request, Rohm and Haas stated that the
proposed tank would comply with the vapor balancing requirements in
NESHAP subpart G, 40 CFR 63.119(g) to confirm proper vapor balancing.
See 86 FR 8618 (February 8, 2021). 40 CFR 63.119(g)(5) identifies an
instrument reading of >=500 ppmv as a leak, which triggers a
requirement to repair as soon as practicable but no later than 5 days
after detection. Rohm and Haas states in its comment that this change
would be consistent with 40 CFR 63.119(g).
The Agency declines to adopt this suggested revision for the
following reason. The EPA equivalency determination is based on the
closed vent system being closed and not leaking under any
circumstances. To ensure equivalency, the Agency is requiring that no
detectable emissions occur from PRDs and components of the vapor
collection system on the tank; accordingly, any leak would be an excess
emission. Therefore, the EPA has not made the change requested by the
commenter.
B. Comment on Paragraph (4)--Clarification on Welded Steel Piping
Rohm and Haas's second comment requests clarification on paragraph
4 of the operating conditions in the initial document, specifically the
requirement that ``VAM must be transferred from either railcars or
truck trailers via welded steel piping into the new bulk storage tank.
The tank must be equipped with a welded steel vapor balance line that
returns displaced vinyl acetate vapors from the headspace within the
tank to the railcar or tank truck during tank filling operations.''
Rohm and Haas states that they intend for the piping to be welded
steel piping but notes that there will be a minimal number of necessary
flanged connections, flanged valves, and flexible coupling lines for
the unloading line and for the vapor balance line. The Agency does not
believe, and Rohm and Hass do not claim, that the operating conditions
in paragraph 4 cannot be met or otherwise need to be changed because of
the presence of these flanged connections, flanged valves, and flexible
coupling lines. The EPA is therefore finalizing the requirements in
paragraph 4 as specified in the initial notice, and we are adding a
statement in the paragraph acknowledging that ``there will be a number
of necessary flanged connections, flanged valves, and flexible coupling
lines as part of the vapor balance line.''
C. Comment on Paragraph (6)--Recordkeeping Requirements
Rohm and Haas's next comment is on paragraph 6 of the operating
conditions in the initial notice, which states that, ``The facility
must keep a record of the equipment to be used and the procedures to be
followed when reloading the railcar, tank truck, or barge and
displacing vapors the storage tank from which the liquid originates, as
well as a record of all components of the PRDs, including PRVs and
rupture discs.''
Rohm and Haas's comment identifies certain inaccuracies in
paragraph 6 in the initial notice. For example, the statement
incorrectly uses the term ``reloading'' in describing the operation of
unloading vinyl acetate from a railcar or tank truck. Rohm and Haas
also suggest removing the reference to a barge because it is not
possible to unload a barge at this facility. In light of the above, we
accept Rohm and Haas's suggestion to revise the statement to read as
follows: ``The facility must keep a record of the equipment to be used
and the procedures to be followed when unloading the railcar or tank
truck and displacing vapors from the storage tank to the transport
vessel from which the liquid originates, as well as a record of all
components of the PRDs, including PRVs and rupture discs.''
C. Comments on Paragraph (7)--Reporting Requirements
Rohm and Haas suggest, and the Agency accepts, minor wording
changes to paragraph 7(a) of the operating conditions in the initial
notice.
Rohm and Haas also suggests several edits to paragraph 7(b), which
requires the facility to report ``The date and time identifying each
period during which the continuous monitoring systems were inoperative
except for zero and span checks and the nature of the system repairs or
adjustments.'' Rohm and Haas requests adding the terms ``pressure'' and
``other required maintenance'' such that the requirement would read as
follows: ``The date and time identifying each period during which the
continuous pressure monitoring systems were inoperative except for zero
and span checks or other required maintenance and the nature of the
system repairs or adjustments.'' The Agency disagrees with adding the
term ``other required maintenance'' because it is important to include
reporting of downtime in monitoring to understand system upsets, and
adding the term ``other required maintenance'' would limit reporting to
only periods of required maintenance, thus excluding downtime. However,
the Agency does agree with the change to add the term ``pressure'' to
specifically refer to the ``continuous pressure monitoring system.''
This edit accurately reflects paragraph 2 of the operating conditions
below and in the initial notice to only require pressure to be
monitored.
Lastly, Rohm and Haas suggests adding ``in this section'' to
Paragraph 7(d) so that it reads: ``When the continuous pressure
monitoring systems have not been inoperative, repaired, or adjusted,
such information shall be stated in this section of the report.'' The
Agency interprets the comment to request that the information required
in paragraph 7(d) be reported in the storage tank section of semiannual
compliance
[[Page 38078]]
reports for this facility. The Agency does not object to making this
addition.
III. AMEL for the Storage Tank
The EPA is approving the AMEL request by Rohm and Haas. Based upon
our review of the AMEL request, the Agency believes that, by complying
with the operating conditions specified in the following paragraphs,
the proposed new tank at the Rohm and Haas Chemicals LLC facility will
achieve emission reductions at least equivalent to reduction in
emissions required by NSPS subpart Kb, 40 CFR 60.112b:
(1) No PRD on the storage tank, or on the railcar or tank truck,
shall open during loading or as a result of diurnal temperature changes
(breathing losses).
(2) Both PRDs on the storage tank must be set to release at no less
than 9 psig at all times. Any release from a PRD as indicated by
pressure reading greater than 9 psig is an excess emissions event. To
demonstrate that the PRD does not open, the tank vapor space pressure
and the space between the rupture disk and PRD will be continuously
monitored for pressure and recorded. If a release occurs, the tank must
follow 40 CFR 63.165(d)(2).
(3) Each of the PRDs and components of the vapor collection system
on the tank must be monitored on a quarterly basis, using EPA Method
21. An instrument reading of 500 parts per million by volume or greater
is an excess emissions event.
(4) VAM must be transferred from either railcars or truck trailers
via welded steel piping into the new bulk storage tank. The tank must
be equipped with a welded steel vapor balance line that returns
displaced vinyl acetate vapors from the headspace within the tank to
the railcar or tank truck during tank filling operations. The vapor
balance line must be hard piped from the tank, crossing a pipe bridge,
before terminating at the off-loading station. While there are a number
of necessary flanged connections, flanged valves, and flexible coupling
lines as part of the vapor balance line, the tank vapor balance line
must not contain any PRDs or release points. Displaced vapors must be
transferred to a vapor return fitting on the offloading bulk vehicle
through a hose from the offloading station. Both the transfer hoses and
the vapor balance return line must incorporate dry-disconnect fittings
to prevent vapor discharge to the atmosphere when the line is not
connected. Tank trucks and railcars must have a current certification
in accordance with the DOT pressure test requirements of 49 CFR part
180 for tank trucks and 49 CFR 173.31 for railcars. Railcars or tank
trucks that deliver VAM to a storage tank must be reloaded or cleaned
at a facility that utilizes the control techniques specified in
paragraph (4)(a) or (b).
(a) The railcar or tank truck must be connected to a closed-vent
system with a control device that reduces inlet emissions of VAM by 95
percent by weight or greater.
(b) A vapor balancing system designed and operated to collect
organic VAM vapor displaced from the tank truck or railcar during
reloading must be used to route the collected HAP vapor to the storage
tank from which the liquid being transferred originated.
(5) Rohm and Haas must submit to the Administrator a written
certification that the reloading or cleaning facility meets the
requirements of paragraph 4; and the requirements for closed vent
system and control device specified at 40 CFR 63.119 through 63.123.
The notification and reporting requirements at 40 CFR 63.122 do not
apply to the owner or operator of the offsite cleaning or reloading
facility.
(6) Recordkeeping requirements.
(a) The facility must keep a record of the equipment to be used and
the procedures to be followed when unloading the railcar or tank truck
and displacing vapors from the storage tank to the transport vessel
from which the liquid originates, as well as a record of all components
of the PRDs, including PRVs and rupture discs.
(b) Records must be kept as long as the storage vessel is in
operation.
(7) Reporting requirements. The facility must submit excess
emissions and monitoring systems performance reports to the
Administrator semiannually. All reports must be postmarked by the 30th
day following the end of each 6-month period. Written reports of excess
emissions must include the following information:
(a) The date and time of commencement and completion of each time
period of excess emissions and the process operating time during the
reporting period.
(b) The date and time identifying each period during which the
continuous pressure monitoring system was inoperative except for zero
and span checks and the nature of the system repairs or adjustments.
(c) The report must include a list of the affected sources or
equipment, an estimate of the volume of VAM emitted, and a description
of the method used to estimate the emissions.
(d) When the continuous pressure monitoring systems have not been
inoperative, repaired, or adjusted, such information shall be stated in
this section of the report.
Dated: July 13, 2021.
Panagiotis Tsirigotis,
Director, Office of Air Quality Planning and Standards.
[FR Doc. 2021-15321 Filed 7-16-21; 8:45 am]
BILLING CODE 6560-50-P
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