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                 •'                  ..     ,
          Notes:           ,      ,;.     ..
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•          •   The data provide'd  in these charts may not  reflect  the  latest  information
          which you may have.  The following notes  identify specific'changes which  should
B  *     be made.  If you have more  recent data, or recognize  any errors', please -notify
        I' the Land Use Planning Branch.                       „
                                  ' ' •         «  •.
         1.1.   More recent air quality data for -the Metropolitan  Philadelphis  Region
                                '    '  '      '  '-     ,'       3
      •  "o      -shows a second high value of 30 ppm  (34 ing/m ) for carbon monoxide.
I  •   e 2.   Louisiana's recently adopted hydrocarbon regulation wi'll provide
               significant reductions from stationary sources.  Transportation controls
•   .          will probably not  be needed.  Air quality  data from Louisiana was used
                                                              t  '
   •                    •                                              *
•  • t.      '  for'this entire Region.  Recent data taken  in the  Texas portion shows
               a second high value of .30 ppm  for oxidants.  This' is  the value which
               Texas will use to  develop a plan for its portion of the Region.
•        '3.'   The'revised Texas  emission inventory shows  a significant change in the
               mobile source contribution to total hydrocarbons.  The ratio of mobile
I             to total emissions is  now .14.  Transportation controls.will therefore
           .  •  have less of an effect on total emission reductions. ,  The same  type
™     •        ratio for the Houston-Galveston Region also changed, and now is .16.
            •                  •                                        *
•             'Stationary source  controls must obtain significant reductions in  these
               two Regions if the NAAQS are to be achieved by'May 31, 1972.
I    '    4.   The^air quality data used for these calculations are second high  values.
•               However, the California Air Resources Board wi'll use the maximum  values
           .
               of .46 ppm and .40 ppn for the  Southeast Desert  and San Diego Regions
                              I- - • -            .
               respectively in developing their plans-.

I                .       "                •        '       /
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                  UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                     Office of Air Quality Planning and Standards
                     Research Triangle Park, North'Carolina 27711

  "HjECT:  Format for the Review and Evaluation of Transpor-     DATE:  March 28  1973
          tation Control Plans    •                                             *
 TO:       Transportation Planning Representatives
          Regions I-X

               At the meeting of Air and Water Program directors  and  transpor-
          tation planning representatives in Chicago  on March  20,  1973,  Dr.
          Tom Wright of TR1-I Systems, Incorporated,  handed out  two  documents
          that pertained to TRW's Basic Ordering Agreement No.  68-02-0048,
          Task Order No. 14.

               One document was a 20-page set of tables that TRU  plans  to  use
          during their initial  review of the SIPs to  gather data  concerning
          items one and two of the Task Order.   Item  one primarily covers
          the social and economic impacts of transportation controls  while
          item two summarizes the general and specific features of transpor-
          tation control strategies selected by the States.  The  other  document
          furnishes some brief directions for the completion and  use  of the
          tables.

               It was explained at the meeting that these tables  were going  to
          Obe used by TRU and could be used by the Regional  offices if they found
          them useful.   It was' further requested that tne Regional  otnces sena
          comments in to the Land Use Planning Branch concerning  the  adequacy of
          the tables so that these comments could oe  forwaraed 10  "IK'W.

               Dave Tamny,  of the Land Use Planning Branch, has contacted  the
          transportation planning representatives by  phone again  asking for
          comments.   It was his understanding that  if he did not  receive
          comments by March 23, 1973, it meant the  Regional offices had no
          comments regarding the forms/tables to be used by TRW for the review
          and evaluation of the transportation control plans.   •  *

               As of March 27,  "1973, no significant comments have  been  received
          regarding TRW's format for review and evaluation of  transportation
          control plans.  Therefore it is assumed the Regional  offices  have  no
          additional comments and there is no need  to issue revised tables.
                                                   Frederick  Winkler
                                             Land Use  Planning  Branch
EPA Foim 1320-6 (Rev. 6-72)
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                                                               ',,,-
                  UNITED STATES ENViriONMEHTAL PROTECTION
                    .Office of Air Quality PI aim ing and Standards
                     Research Triangle Park, North Carolina 277,11
sbv/jV,CT: Transportation Control Meeting
         (3/30/73 -.Chicago, Illinois)
,.c
DATE: March 28, 1973
FROM:  •'  SASD/I.UPB
TO:
O
         See Addressees
                   I                                             ,
              A meeting was held in Chicago on March 20, 1973, to discuss
         the status of transportation control plan development, and the
         reccirinoided approach to HPA plan development.  All EPA regional
         offices, GAMP, OGC, OAQPS, MSAPC, MSF.D, FHUA and TRW were represented
         at the meeting.   An attendance list is enclosed.

              Also enclosed are the minutes of this meeting.   Questions
         concerning the minutes should be directed to the Land Use Planning
         Branch (Dob Clark:  (919) 688-8291.)  Follow-up on Action Items (see
         enclosure) generated at the meeting is continuing.  Questions
         concerning these items should also be directed to the above.
                                                   Pvonald A.  Venezia
                                                         Chief
                                               Land Use Planning Branch
         Enclosures (3)

         Addressees:

         T.  Cortese
         T.  Dwyer
         I.  Mil nor
         B.  Burch
         E.  Enstrom
         J.  Crocker
         D.  Durst
         J.  Phil brook
         R.  Mueller
         B.J.  Steigerwald
         J.  Padgett
         J.  Horowitz
         J.  Me r-en da
         D.  Hanson
         D.  Grahani
         H.  Gompf     ;
         T.  Wright    i
EPA Coim 1320-6 (Rev. 6-7?)
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 o
                                        AGENDA
                            Transportation  Control Meeting
                          Chicago',  Illinois - March  20,  1973
O
       10:00    Welcome  from Region  V
          .
       10:05   tOpening  Remarks
        10:15
        Regional Status Reports
        (Ten minutes each)
1:00

1:15

1:30

1:45

2:00


2:15

2: l\ 5

3:15

3:30
                                               (B.J. Steiger^ald)

                                               , (Region^ I-X)
                Region IX will  also  discuss L.A.  Hearings  (Twenty minutes total)
        12:00-   Lunch
         1:00
Review of SIP Task Schedule
         •

Guidance for Writing Transportation Plans
(Venezia)

(Armstrong)
                 Hydrocarbon Emission Inventory  and Controls  4   (Armstrong arid Horowitz)
                 EPA Proposed Strategies
                                         o
                 Enforceability of Transportation Control
                 Strategies

                 Basis  for Extensions

                 Transportation Regulations ~  Appendix N
                                •

                 Evaluation Reports

                 Discussion
                                               (Venezia)   . •  «



                                               (Graham)
                                                              •

                                               (Trick)

                                               (Armstrong and Mcrenda)
                                                           •
                                               (Venezia)             ,
         5:OC  .  Adjourn
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  I
Transportation Control N.oosures, tmcago i\\.
•   .        '•    March 20, 1973        •  •   !
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 Name.       :
 Wallace VJoo
 Tony Cortese
 Israel Milner
 Chuck Miesse
 Bill Burch
 Lance Vins'on
 'Ed Enstrom
 Ed Muse .
 Manuel Marks
 Jack'Chicca
 "Diana Dutton
. John Crocker
 Dewayne Durst
 Irwin L. Uickstein
 'Charles W. Hurray  Or.
 John Phil brook
 Ron Mueller
 B.O. Steigerwald
 0. Padgett
 Ronald Venezia
 •Donald Armstrong
 David Tamnyt
 Robert Clark
 Ooel Horowitz
 Joe Korenda
 Dave Hanson
 David B. Graham
 Dick Kozlowskii
           •   i
 Henry Gompf
 Tom Uriqht
                       ' Organization^     '
                         Region I - EPA
                         Region I - EPA
                         Region II - EPA
                         .Region III - EPA-
                         Region III - EPA
                         Region IV - EPA
                         Region V - FHUA
                         Region V - FHWA
                         •Region V - EPA
                         Region V - EPA
                         Region V.-EPA •
                         Region VI - EPA
                         Region VI - EPA  .
                         Region VII - EPA.
                         'Region VIII - EPA
                         .Region VIII - EPA
                         Region VIII - EPA
                        [.Region IX--EPA
                         OAQPS, Durham
                         OAQPS, Durham
                         LUP.B, Durham
                         LUPB, Durham
                        . LUPB, Durham   .
                         LUPB, Durham
                         DAMP
                         OAWP>
                         OAWP
                         USED
                         MSED
                         MSAPC
                         TRV!
     Telephone
617-223-5609
617-223-5630
212-264-9800
215-597-9164
215-597-9303
404-526-3285
312-253-1471  '
312-353-6942
312-799-6300
312-799-6300

214-749-2142
214-749-1231
816-374-3791
513-837-3868
513-837,:4871.
305-837-4831
415-556-2332
919-688-8576
919-688-8204
919-688-8291
919-688-8291
919-688-8291
919-688-8291
202-755-0630
202-755-0650
202-755-0460
202-755-2598
202-755-2518
313-761-5230
703-893-2000
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                                  MINUTES

                      Transportation Control Meeting

                      Chicago, 111. -'March 20, 1973
                                       •                    •  •
o"        '
    I.  Ronion Office Summaries         '                             «
     «  —j	                                      .       •
                         c
        Region I:                            .                       %
                 •                                        •  *   « «          «
          A. • Metropolitan Boston              "                         "

              1.  New air quality data for this AQCR (.25  - .26ppm)  in-
         •       . dlcatcs that a reduction in  hydrocarbons of 86% will-be
     ,          o   required based on App. J of  the Federal  Register. Region
       «    ,   ,°   I is considering letting the State use°a proportional
                  rollback for calculating the required reduction (about 70%).
          '«
 .  «       '2.. 'Region I expects the State to submit only a token  plan.
                 • Therefore, EPA promulgation  is likely.

          B.  Hartford - New Haven - Springfield
                                            <•
              1.  Region I expects that the State will not submit a  plan
                  for this AQCR until June.  6CA has been  contracted by
                  Region I to-prepare an EPA plan.
     .           * -                                         .                    «
        Region II: .          »
                                            •,
          A.  New York - New Jersey -^Connecticut                    ••  «
                                  t
              1.  New York and New Jersey are  using air quality data in
                  their respective portions of this AQCR for.plan development.

              2.  New York and New Jersey will be meeting  to  discuss reciprocal
                  transportation control strategies.  Region  II requested
                  advice on EPA's position on  such strategies for interstate
                  regions'.
                                                              i

              3.  Region II expects a  late submittal from  New Jersey.   Clari-
                  fication was requested on how this would be handled  in
                  Federal Register notices.
                                           «
              4.  No hearings for New Jersey's plan have been scheduled.

          B.  Metropolitan Philadelphia
                                         .            •

            * 1.  Pennsylvania and New Jersey  are using air quality  data from
                  their respective portions of this AQCR for  plan development.
                     *--*"-            *                                  „•
              2.  Region II dxpects 3  late submittal -from  New Jersey.   Mo
              •  -'hearings have bo on :.>. u-jdulcd tor the plan.
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  ™             , Region  III:
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O             A. •  National  Capital/        •                               '

                    1.   Results of the preliminary review of the plan for this
                        AQCR indicate that no EPA promulgation will  be necessary.
                        However,  minor changes to the plan have been requested
                        by Region III.

   •                2.   Based on  new air quality data (.20 ppni), Virginia wi.ll
      * •      .         submit a  transportation'control  plan for photochemical
                        oxidants.  A special  session of the State.legislature
   °              c       must be called to approve the necessary legal authority.
                                              o
    *  •         •    3. ''Virginia  is considering gas rationing as a  back-up
                        strategy  for its portion of this AQCR.
                *               •                                      *
                B.   Metropolitan  Baltimore

                 •   1.   Region III anticipates an extension -request for this
                        AQCR.   It is expected that such a request will be justified.

                    2.   No promulgation is expected for this AQCR.

                C.   Metropolitan  Philadelphia
               c      '
                  1 1.   Region Ill-expects a  justifiable extension  request for
                        this AQCR.  No EPA promulgation is anticipated.

                D.   Southwest Pennsylvania

                    1. . Region III expects a  justifiable extension  request-for this
                        AQCR.   No EPA promulgation is anticipated.

              Region IV:
                                                 *                           •     .
                A.   Metropolitan  Birmingham
                                                                »         .
                    1.   Region IV does not expect that transportation controls will
                        be required for this  AQCR.

                B.   Mobile - Pensacola - Panama City
1
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                    C.  Regions  IV thinks  that  there may  be  carbon monoxide  problems
                        in Atlanta and Miami.   However, no steps  have* been taken  to call
                        for a  revision to  the plans for these  AQCR's.
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          Region  V:

.           A. ' Metropolitan  Chicago
                1.   Public  hearing  dates  have  been  announced  for this
                    AQCR.   The  basis for the  plan  is  a  city  -developed
          /         Inspection/maintenance program.  There  may  be conflict
                    with  State  authority/responsibility  for the plan.
                    Region  V  does not  think  that  the State  has  authority
                    to  take over the program if the  City, defaults.
          .
                2.   Region  V  questions the method used to device emissions
             •       from  heavy  duty vehicles.   If the  method  is not  acceptable,
              •  -.  <(a'larger  reduction of carbon  monoxide would be required.
           •
                                            '   .                 e
           B.   Metropolitan  Dayton                          c  .

                1.   The State has revised the  emissions  inventory and  will
                    use more  recent air quality data for oxidants,   Region  V
                    expects the NAAQS  to  be  met in  this  'AQCR  by 1975 without
                    transportation  controls.   However, an inspection/main-
                    tenance progrnm will  probably be implemented by  the  State.
                                                         °         •    .
           Q.   Metropolitan  Cincinnati
                                               c
         * I •*
           *     1. *  The emissions inventory  has-been revised  and mobile  source
                    emissions recalculated.  As a result, Region V expects
                    that  stationary source controls  in this AQCR will  be
                ~~"  sufficient  to allow attainment  of  the NAAQS by 1975.

           D.   Metropolitan  Toledo

                1.   As  a  result of  emission  inventory  and mobile source  emission
                    revisions,  Region  V expc-cts the  NAAQS to  be met  by 1975
                    without transportation controls.
                                                                        •     .
           E.   Minneapolis - St. Paul                i
                                                                      *
                1,   As  a  result of  new air quality  data, Region V expects  the
                    NAAQS to  be met by 1975.  GCA has  been  contracted  by
                    Region  V  to rework the transportation data  base  for  this  AQCR.
                                                             *
                                                            •
          •                                        .
          Region VI:                                '
                                                    1
           A.   Southern  Louisiana  - Southeast Texas '
                                                             •
                                      •"*   "         i
                1.   Based on  recently  adopted  stationary source controls by
                    the State,  Louisiana  is  not expected to noed transportation
                    controls  for its portion of this AQCR.
                                                    !
           B.   Texas will-not  submit  a plan containing  transportation controls.
                The  Stale claims that  'the: N/'AOS  can  bo met  in all applicable
                AQCR'r,  through  more stringent'stationary source control:: v;!rich
                have been adopted.   Region VI  does'not expect that stationary
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O                       source  controls  alone  will  bo  sufficient.  .Consequently,
                     •''Region  VI  con s.i do ring  contractor  assistance!  for  preparation
m     .                of a  transportation  conlroTplan  for  Texas.i
I                   '                                            ,     '
         .   .       C.•  Region  VI  expressed  concern for a potential  problem  in  the
        ,-       •  /     El  Paso -  Las  Cruces - Alamogardo AQCR.  Emissions from Mexico
•           ,         may prevent  NAAQS  from being met  in this AQCR.         *      .
                   D.,  Texas  will  held  public  hearings-on  April  4,  1973  to  obtain
                       public reaction  to  transportation controls.   No specific
                     c strategies  will  be  recommended.  The  only purpose of this effort
                       is  to  get. public opinion  if "transportation controls  were
                    .,   implemented.        '
                  *       :  '      •          6    *       t                      *
                 Region 0VII:  „                    •

                   A.   Metropolitan  Kansas. City            *

                       1.-   Region  VII expects  that  a  10% reduction  in total  carbon
                         'monoxide  emissions  will  have'to be  realized from trans-
                    '       portation controls  in this  AQCR.  Region VII  thinks that
                    :      'a  short extension  (7  months) can  be justified.

                       2.   P£DCo has been  contracted  by Region VII  to revise mobile
                           source  emissions..
                                                                i
                 Region VIII:            •         -.   •
                    ;    "   -        .  *                         •
                   A.   Wasatch Front
                                                                              • • '

                       1.   Region  VIII  expects to have to  promulgate a plan for  this
                           AQCR.

                       2.   New air quality data  indicates  a  CO problem in Ogden  similar
                           to the  one in Salt  Lake  City.

                   B.   Metropolitan  Denver

                    1   Region  VIII has  doubts  as to whether  Denver's preliminary plan
 P                   '  1s sufficient for meeting NAAQS by 1975.  The state has proposed
                        stationary source controls which will provide some help in getting
 H                     the necessary hydrocarbon reductions.

 .                 Region IX:              '                •         •
                  A,  No hearing  dates  have  been  announced  by. California.   Region  IX
                    >0 does not expect a plan  submittal  until  June.  -

                  B.  California's  current  inspection/maintenance  program is  designed
                      to randomly select 15%  of the  L.A. vehicle population.   The  State
                      is considering a  50/'  rejection.
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        C.   With  the exception  of  Los Angeles,  Region  IX considers  the
           'San Diego  and  San  Francisco AQCR's  as most critical.  The
            Southeast  Desert AQCR  problem  is  considered a  carry-over of
            the Los Angeles problcml                        •        •

     •   D.   Phoenix -  Tucson
                                                                         .  •
               Region IX  has  discussed new emission inventory  calculations
  «             with the State.  Plan submittal  is expected on  April 15,  1973.
              *                                         fc   '  «           v
                                            o
        E.  ' Clark - .Mohave             9                            •  '
                                                                   €   t
  "             Emission reductions .assumed for transportation  controls in
              •.Nevada's SIP are too high  compared to  that allowable'under .
            «  the proposed guidelines.   In  addition  the  State's committment
    •   <  -   to implement'the strategies set forth  in the  SIP is question-
               able.   Consequently, Region IX  expects that a re-evaluation
               ,of the SIP would prove it  to  be inadequate for  meeting the
             • NAAQS  by 1975.'

     Region X:             '

     ..Washington has the legal authority to implement an inspection/mainr
        tenance program.   However, lack of a  vehicle safety inspection
      x  program would  make it  very difficult  for such  a strategy by  1975.

 II.  Plan  Review Schedule    •                          *                    '
                 *                                   *
                                          *
     A.     One of the main points of discussion was the importance of having
            the FHWA participate in  plan reviews and any EPA  plan development;
            Generally, FHWA  and Region personnel have  had  only  limited contact.
            The Regions were urged to actively  pursue  participation by  FHWA
            both  in plan review and  development.  FHWA representatives  at the
            meeting expressed  a desire to  participate  and  a willingness  to
            assist EPA.

     B.     The Regions were reminded that preliminary as  well  as  final  plans
            were  to be sent  to all reviewers  for comments.  Comments should
            be returned to the Regions as  soon  as  possible.

     C.    The Regions are  supposed to  notify  OGC (Bill  Frick) immediately
            on receipt of  plans.

111.' Guidance for Writing Plans                       •

     A.     The recommended  approach to  preparing  an EPA.plan was  presented
         •  (See  attachment  I).  During  the ensuing discussion, the avail-
            ability of various retrofit  hardware and implementability of
           •Inspection/maintenance programs were questioned.   It was.generally
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           agreed that the'VSAD and LIAF options  would  bo  available
           and implemcntablc by 1975.  -There  was  disagrepment,  however,
           on the availability and'implementability  of  the EGR  and
           catalytic converter options.   This disagreement led  to the
           question of whether a State's plan should be 'approved  if  one
           or, both of these options were included as part  of  the  overall
  *        ^trategy for NAAQS attainment by 1975.  HSPCP  pointed  out     •   •
'„         'that the proposed Appendix  N  required  States to substantiate
           the-availability of such retrofits and provide  assurance  that  imple-
          mentation could be achieved by the required  deadline.  If these
          .requirements were satisfied,- then  there would  be no  grounds for
 «         disapproval.    "
          1                         •
              .         •          •    •                         *   •
     B.     The" ability of States to have operational inspection/maintenance
   •    . ; programs by 1975 was questioned, especially-  for those  states
        -:  which do not now have safety  inspection programs.  MSPCP  agreed
        ••  to provide information on the steps required to develop an
           inspection/maintenance program and an  estimate  of  the  time
        I  needed for each phase of development.   This  information should
        i  be available early in the week of  March 26.

IV.  Enforceability of Strategies  '

     Dave  Graham*(MSED) provided^a memorandum concerning  this subject.

  •     \     '  '              .         .                 .
 V.  Basis for Extensions -
                                         •.
     A.     The following information on  attainment date extensions.was
           provided by OGC.    .                                                ,

           1.  Adequacy of extension justifications  must  be determined for
               each specific case.

           2.  Although a maximum extension of two years may  be granted,  EPA
               must ensure that States attain NAAQS  as  expeditiously as
        ,       practicable.
        I              .  •                                   '
           3.  To be granted an extension (of any length)  a State must have"
               considered all available  alternatives.
                                      i                           *
       !                                                                      •
           4;  It would be very difficult for EPA to grant an extension  reques
       !        which is based on social  impact.
                                 •*•   *
     B. i    An interesting point was brought out during  the discussion on  plan
           extensions.  If EPA proposed  a plan which included an  extension,
        *   then this would essentially be a garranteed  extension  for the  State
           if the..State in turn submitted a late  plan.
!•
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O
  VI.   Evaluation Reports
                       /               •
       A checklist (prepared by TRW)  for'plan review as part of •
       TRW's impact analysis was'handed out to all  reviewers.
       Comments concerning this checklist should be returned to
    ,   LUPB as soon as possible in order to make the list as
       useful as possible for TRW.  Reviewers may also use this
       checklist as necessary in their review of SIPs.

 VII.   Transportation Regulations.- Appendix N"                 «
                          •  .
       A.  All numbers of reflecting allowable reductions for the
     ,     various control measures are to be used as a guide until
       . .  Appendix N has been officially approved.
           «•                                                   •
    •
       B.  MSPCP pointed out that failure rates for inspection/
    '  .     maintenance programs are for individual  pollutants.
 °    -     For example, the worst 30% of hydrocarbon emitters
           may not necessarily be the worth 30% of carbon monoxide
           emitters.   It is possible then, to have more than 3Q%
           of the vehicle population fail  if vehicles are tested for
           hydrocarbons and carbon monoxide.

VII.   Action Items
    4 •«-                                            .

       A list of action items were identified as a result of the
       various questions raised, points of disagreement, and
       requests for guidance.  This list, which includes the
       responsible agency, is provided in Attachment 2.
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I

I

I
    II                             GUIDELINES FOR WAIVERS  OF EMISSION
    J                              TESTING IN FACILITIES  INVOLVING
    J                                           BERYLLIUM
I
     ,                         I.   Introduction
*  <                         These guidelines cover requirements  necessary to  qualify
—   '                                                                                 i
•                            for a waiver of emission  testing  for beryllium extraction
      '                        plants, machine shops, ceramic plants, foundries, and
I    •                        others processing beryllium-containing materials.
      I
                                  1.  Beryllium Emission Limit
I                                  According to Section 61.32, Suupart  C, of the National
      !
      j                        Emission Standards for Hazardous  A1r Pollutants,  total
mt  ••                        effluents emitted to the atmosphere  from a source must  be
m                            controlled so as to limit beryllium  emissions to  a maximum
™                            of 10 grams in a 24-hour period,
•                                2.  Waiver of Emission Tests
                                  Emission tests - initial, periodic or both -  may be
                    1          waived upon written application to the Administrator,  if in
I                              his judgement the source is  meeting  the  applicable emission
      i         .               limits or 1f the source 1s operating under a waiver of
 •    ,                        compliance or has requested  a waiver of  compliance.

 |    !                        Sources not meeting the requirements of  II(a) below may

 I
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 apply for waiver of emission  testing.   The  decision  on
 the application  will  be based on  the amount of material
 processed, the  type of operation, the  type  of control
 system Installed and special  factors pertinent to that
 source.
II.  General Waiver Qualifications
 The following requirements  are necessary to qualify  for
 a waiver of emission testing  and  recordkeeplng required
 by the National  Emission Standards for Hazardous  A1r
 Pollutants, Section 61.13.

     a*  Sources  which certify that less than 10 pounds per
     month of beryllium 1s processed will automatically
     be granted  a waiver of both Initial and periodic
     emission testing.
     b.  The source must be controlled  so that the total
     effluents emitted to the  atmosphere do not contain
     more than 10 grams of beryllium 1n a 24 hour  period.
     c.  Control  equipment and operation thereof must be
     correctly represented 1n  the waiver request application
     and must continue to exist and be  operated as was
     represented.  If source test results were submitted
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I

I
                                  with  the  waiver  application,  collection efficiencies
M                                shall  continue to  equal  or  exceed  those claimed  1n
•                                the application.
     I                       III.   Required  Information  for Waiver  of Emission  Testing
I
                              The following specific Information concerning  the  beryllium
                              control systems  with which  the  facility is attempting to
m                            qualify for a waiver must be supplied  with the waiver
                              application.
•                                1.  Process  Information
™   i
                                  a.  Complete flow  diagrams  of all  operations contributing
I
                                  to  emissions.  Include  material  balances.
                                  b.  Estimated flow rate,  composition, temperature, and
^                                other pertinent  Information on atmospheric emissions.
                                  c.  Location and number of  emission points.
I
                                  d.  Operations considered to be  the major  sources of
                                  emissions.
I                                e.  Process  calculations having  any bearing  on emissions
                                  and emission rates.

                                  f.  Effects  of startup, shutdown and abnormal  operation
1
I
                                  on emission  rates.   Description  of process  instrumentation
                                  which can  correct overloads  or failures  (such  as  alarm
-1
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    for ruptured prefliter or an override  on  a  recording
    flow control to a baghouse).

    2»  Control  Equipment Information
    a.  Engineering design calculations,  including assumptions,
    operation principle, and operating variables  affecting
    performance  and efficiency,
    b«  Manufacturer and ntudel number.

    c.  Equipment specifications including:   design capacity,
    guaranteed efficiency, performance, operating instructions.
    Include,, where applicable, information such as:
    allowable pressure d,-  . ,  gas velocity, filter ratio,
    temperature, partlculate gas loading,  etc.

    d.  Equipment drawings*.
    e,  Engineering drawings of control equipment as
    Installed; wHh ductst hoods, fans, piping and other    <
    auxl S ic»f>., *.
                                                             \
    f,,  Spare pa^ts wn'.ch a^e proposed.
    g,  Scheduled maintefsance procedures,
    3,  Source Tests for Emission
    If requested, the results of an emission test  performed
according to EPA-approveo sampling and analytical  techniques
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I
                             published with the standard must be Included 1n the waiver
•                           application.  All reports should Include the name and
     ,                       telephone number of a company representative who can be
I
•

I
                             contacted to clarify any Information submitted.
                            IV.  Suggested Procedures for Applicants for Waiver of
                             Emission Testing
_

                             The following maintenance and Inspection procedures,
•                           where applicable, are suggested for those sources applying
•                           or qualifying for a waiver of emission testing.

-                               1.  Fabric Filters
                                 The following maintenance and operating procedures
                             «hall be adhered to wherever fabric filters (baghouses)
                             are utilized to control emissions regardless of their
                             position 1n any specific control arrangement.

                             Dally Inspections
                                 1.  The clean side of all baghouses must be Inspected
                             for leaky, torn, or poorly sealed bags.  In cases where
•                           sufficient light 1s not available to properly  Inspect
                             all bags, a portable light source shall be used.

                                 2.  All dust tubes shall be Inspected for  abrasion
ft  .                         or wear.

                                 3.  The clean side of the cell plant  floor shall be
-------
Inspected for any dust accumulation.   Dust build-up 1n this
area 1s evidence of leaky fabric filters or cell  plate joints.

Weekly Inspections
    1,  The baghouse housing shall be Inspected for air
leaks and all Interior sections checked for excessive
abrasion or wear.
    2.  The shaker mechanism shall be Inspected for
proper condition.

    3.  All fans, drivers, and power equipment shall be
Inspected for wear, damaged parts and leaks.

General Maintenance
    1.  All maintenance and Inspection requirements
cited by the manufacturer of the subject control equipment
shall be strictly adhered to with the exception of those
that require fewer Inspections to be performed than cited
In this document.

    2.  Periodic Inspection of the dust collector housing
and structural components 1s required.  All bolts shall be
Inspected and tightened and Inspection door seals checked
for leaks.

    3.  Upon determination of any unsatisfactory conditions
of control equipment. Immediate correction action shall be
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                               taken.  In order to avoid excessive emissions  and/or loss
                               of operating time, a supply of spare parts shall  be
                               maintained.  Control equipment manufacturers should
                               provide recommendations as to which parts  should  be kept
 I                            on hand.  In all cases, enough wearable parts  and fabric
 m                            filters should be stocked to equip one baghouse or one
                               compartment of a baghouse.
 •»
Fabric Filter Material and Construction
                         *
In the event filter material, filter construction, or any

control or process variable that may adversely affect
 m
      I                         collection efficiency or increase total  emissions 1s
 •                            changed after a source test waiver has been granted, the
                               waiver 1s cancelled until  these changes  have been approved
 m                            by the Administrator.

 |                                2.  HEPA Filters
 _                                The following maintenance and operating procedures
 *                            shall  be adhered to wherever HEPA (High  Efficiency Partlculate
 •                            A1r) filters are utilized as the final emission control
                               device 1n any control arrangement.
                               Maintenance
 •                                 1,  Filters and mounting frames shall be visually
                               Inspected on a dally basis for damage or defects.  Special
 •   j                         attention shall be paid to the assurance of a proper

i   '

i
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filter seal to the frame, condition of frame clamps, and
any obvious damage to both frame and filters.

    2,  Pre-fliter banks shall  be visually Inspected
on a weekly basis for damage or defects.   Special  attention
shall be paid to the clean side of pre-fliter banks where
any leaks may be Indicated by the presence of soiled or
discolored areas.

    3.  The filter housing shall be Inspected for  air
leaks and damaged or corroded areas that may result 1n
filter damage and the reduction of both filter efficiency
and life.

    4.  Prior to Installation of HEPA filter, the  following
Inspections shall be performed.  A record shall be retained
verifying performance of such Inspection for the period
1n which the filter is 1n service.
    a*  Exposed filter areas shall be visually Inspected
    with the aid of a strong light source for cracks,
    plnholes, and breaks.  Special attention shall be
    paid to the presence of cracks or breaks on the edge
    of the filter pleats and the adhesive seal around
    the filter unit face.

    b.  The filter case gasket shall be Inspected for non-
    uniformity of thickness, Improperly formed comers,
                          8
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I

I
  ,
                                 •Incomplete  bond  to  the  filter housing, degraded
                           normal  plant operations.
I
m  ,                             6.   Upon determination  of any unsatisfactory  conditions
    I!
                             of control equipment, Immediate corrective action shall
    j                         be taken.  Exhaust gases normally passed  through  HEPA
    I;
                             filters prior to  entering the atmosphere  shall  not be
f                           emitted 1n the event the HEPA filter  control  arrangement
                             Is defective or damaged 1n  any way that may affect filter
•                           efficiency.  Such conditions Include, but are not limited
                             to, those cited 1n this document with respect to  the
I                           HEPA filter and/or the HEPA filter bank.
 I
_

I
                            HEPA Filter Material and Construction
    Ij                         In the event filter material,  construction,  specifications,
    |
    I                         or any control  or process variable that may  adversely
 I  *                         affect collection efficiency or Increase total  emissions
                             1s changed after a source test waiver has been  granted,
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Mf
the waiver 1s cancelled until these changes have been
approved by the Administrator.

V.  Evaluation of Information Submitted with Testing
Waiver Application

The application examiner can automatically grant a waiver
for cases covered by II(a) above.  In other cases, he
must be convinced that beryllium emissions have been or
will be kept within the limits shown 1n II(b).  The safest
course 1s to act upon the evidence of actual source tests
submitted with the waiver application.  Here, the examiner
must convince himself that the data are truly representative
and not accidentally low.
In the absence of source tests, the safest course 1s
to realize that control equipment will probably operate
satisfactorily 1f 1t has a history of good operation
1n similar duties elsewhere.  Accordingly, we hereby
present Figures 1 through 8.  These figures show
the controls used 1n several beryllium machine shops and
a foundry and ceramic plant.  All of these sources were
tested by EPA and were found to be well-controlled.  These
figures are given for perspective, however, and should not
be used to judge waiver applications.

The Information received with an emission testing waiver
application should be evaluated by an experienced engineer.
                          10
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1
I

I
1* • <
1
1

1

•
I
1


FIGURE 1



i
SOURCES AND CONTROLS \


1. Beryllium Machine Shops
Emission Point A2
.
	 unip ^01 lecLiun
MarhinP1; 9 lathes 	 i 	 ; ...
in Material - ' — 	 	 __ r~~"j
Operation Be 	 j~~~[
__ r~-i
i 	 1




<— .I
i i
ST3 — ' /~^» •
r f

Baghouse


"1
jl I


Test! Point <
i


rV
1 •
I i
	 s

y
i 1

Number of bags 45 45
1

1

1

1
M



1
1
1 '
I


61 61

Total cloth area 188 188 383 383
(ft2)
Avg. air to cloth
ratio ft
Avg. total
(min)
flow
rate (cfm)
4.3



4800
Fabric specifications:
Material
- silicon treated cotton
weave - 12
Thread count - 78 x 70
Permeability - 4-4.5 cfm/ft2
Max. temp. - 180°F



1
j
1











I



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                                                                       Test Point
                                    FIGURE 2
      Emission Point Al
Machines in Operation
t
9 mills
Material - Be


Chip Collection
i — -H 	 i

4
Number of bags > 61
Total cloth area (ft2) 383
Jaghouse
^"
6'
3*

L
13
\^^
                             Avg. air to cloth            2.8
                              ra tio'( ft/mi n)
                             Total flow rate (cfm) 1600
                             Fabric  Specifications: same as A2
                                           12
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                                    FIGURE 3
     Emission Point A3
                                                              A-3    
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Emission Point Bl
      Machines in
       operation
      15 Lathes
      13 Dry
       2 Wet
      Material Be
Emission Point 82
                               FIGURE 4
                    Avg. flow rate (cfm) 2960
         Test
        Point
 CP
Baghouse
                                                                  •e-
     Machines in
     operation
    2 Grinder,
    wet
    Material BeO
                    Avg.  flow rate  (cfm) 920
                                  14
                                                                   Test
                                                                  Point
   Baghbuse
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I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
I
                             FIGURE 5
   -:-:-,i.-.. r'o!:tt 3-3
  Operations
3 mills-wet
2 ultra sonic-wet
1 lathe dry
1 Grinder-wet
material BeO.Be
        Test
       Point
Baghouse
                      Avg.  flow rate (cfm) 1875
                                     15
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                           FIGURE  6
2.  Beryllium-Copper Foundry
    Test Point C]
    Emission Point
            cooling
                                     Test
                                    Point

                                      V
                                    Cyclone
                                                 Test
                                                Point
                                                              Bag-
                                                              House
Avg. flow rate (cfm) 20,435
Permeability ft/min 15-25
Material            Dacron
Total filter area (ft2) 7,986
Fabric count        78 x 74
Air to cloth ratio (ft/min) 2.5
                                   16
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                           FIGURE 7
3.  Beryllium Oxide Ceramic  Plant

    Emission Point D-l


Operations

Machining
Grinding
Formi ng
Weighing
etc.
Mt. BeO

nrs/uay





























\r
i
(T
L

_
1

0— i
t—

n
l_;

i
i












<= 	




r
r
c.






n i Te!
) Pnii










I
1
1
i
<
5t
->4-
It



(







                                 \
                                    Pre-Filters
                                             HEPA  Filter
                                             Dimensions (ft) 4'x4'xT
                                             Avg.  Flow Rate  (cfm)  18,900
                                   17
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Emission Point D-2
                             FIGURE 8
Spray
Drier
40 Ibs
BeO/hr.
r



C
I
\>
I
                                              Baghouse
                                              Reverse
                                                  Jet
                                                                 Test  ^
                                                                Point  v>
                      HEPA
                      Filter
                              Bag Material  -  Dacron, Silicon treated
                              Avg.  flow rate  (cfm)  - 1,857
                              Cleaning  Cyclo  -  2  ea.,  5 sec. pulses per min.
Emission Point 0-3
      Calciner
     250-660°C
   Zone Heating
                  I
 Test
Point
                                Pre
                               Filter
HEPA
Filter
                                     18
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I
I
I
                              This can be performed 1n as much detail as manpower
8    I                        will allow, consistent with the number and complexity of
                              emission points and control devices.  As a minimum, the
                              evaluator must match gas flows from the material
                              balance to the available area of the various filtering
                              devices proposed and given in the vendors specifications.
                              Beryllium extraction plants have all been designed to
                              limit ambient concentrations of beryllium to 0.01
                              micrograms/cu meter and have demonstrated the capability for
                              operation within this limit.  They have a great variety
                              of potential beryllium emission sources.  Appropriate
                              practices for control o* fmissions include:

                                   1.  Ventilation hoods of very careful design.

                                   2.  Removal of larger partlculates by prefilter,
                                   followed by HEPA filter for fines.

                                   3.  High energy wet collectors.

                              The  following general comments may act as a guide to
                              the  waiver evaluator.

                                   1.  Wet Collectors

                                   In general, wet collectors are applied in beryllium
                              handling to remove hot, wet, sticky, agglomerating, hygroscopic,
                              or inflammable materials from a gas stream.  Efficiency is
                              not  high enough to remove submicron particles satisfactorily.
                                                       19  .
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    2.  Fabric Filters

    These devices have over 99 percent efficiency for
ore handling operations of crushing and milling, and for
handling dry beryllium hydroxide.  They are used to
control emissions from conversion of beryllium metal
billets to metal forms; and of beryllium hydroxide to
alloys, oxide powder, and ceramics.  They depend upon
use of filter aids and buildup of a cake, for their
highest efficiency*  Oaoron, Orion and nylon are used
for fine partlculates because cotton sateen bags are more
easily blinded by fine dusts.  The usual filter ratios are
1:1 to 1:3 cfm/sq ft cloth area, and operating pressure
drop range 1s about 2" - 8" H-O.
The choice of an effective filter can be made with
confidence only on the basis of previous successful
operating experience with a similar system.  Otherwise,
the determination of a satisfactory combination of filter
fabric and bag cleaning system should be considered as
a development program, rather than as an engineering task.
                          20
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    3.  Prefliters

    These filters are frequently utilized to protect
HEPA filters from high partlculate concentrations.  They
can be designed to collect high concentrations  of the
larger particulates; this statement applies  particularly
                                                        I
to the viscuous  impingement panel type.   There are
two other, extended medium, dry type prefliters which
operate at higher pressure drops and have higher dust
collection efficiencies.  Some idea of the nominal
values of air handling capacity, pressure loss  and dust
holding capacity of prefilters is given by Table 1.
The cited dust holding capacities are those  for Cottrell
precipHator dust as determined by NBS test  method.   The
properties of a beryllium dust might produce a  considerably
different dust holding capacity.
                          21
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    4.  HEPA (High Efficiency Participate A1r) Filters

    This 1s a filter  with very extended surface.  The
filtering  medium (a special fibre glass or paper sheet) 1s
wrapped 1n an S pattern across corrugated metal or ceramic
spacers which support the fragile filter sheet and
maintain the appropriate spacing between adjacent faces of
the filter medium.  The dusty gas enters the filter
at the covered edges of the paper supports, flows Inward
parallel to the paper, and then passes at right angles
thru the numerous layers of filter sheet.
The HEPA filter 1s defined by the following specifications:

    a.  It 1s an extended-medium, dry, throw-away type.

    b.  Collection efficiency 1s at least 99.97 percent
    for partlculates of 0.3 micron diameter.
    c.  Clean flow resistance at rated air flow capacity
    Is no larger than 1.0 Inch w.g.
    d.  A rigid housing extends the entire length of the
    filter medium.

The waiver evaluator should compare the proposed air flow
to the filter with that 1n the vendors recommendations.
                           23
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       Overpressurlzatlon of HEPA filters for even  short periods
       of time can rupture the filter medium, or  even  cause
       complete blowout of the filter core.   Instrumentation
       should exist to prevent excessive airflows leading to
       filter damage.   The shock overpressure resistance, which
       1s the maximum  short-duration overpressure that a filter
       can sustain with no visible damage and no  decrease 1n
       collection efficiency, 1s shown 1n Table 2.
Table 2.  SHOCK OVERPRESSURE RESISTANCE OF OPEN-FACE HEPA FILTERS
                                Overpressure (pslg)
Filter
Dimensions. (In
Face
8 by 8
8 by 8
12 by 12
24 by 24
24 by 24
A
Tepth
3 1/16
5 7/8
5 7/8
5 7/8
11 1/2
Test
Vilua*
3.6
4.5
3.6
2.2
3.2
Recommended .
Design L1m1tD
With Face
Guards
3.1
3.8
3.1
1.9
2.7
Without Face
Guards
2.0
2.5
2.0
1.2
1.8
"dean filter with 4 by 4 mesh face guards on both faces.
bD1rty filters.
                                 24
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 I

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 I
 •   ^                        The nominal dust-holding capacity of HEPA filters varies
                               with the type of particulates, but 1s approximately 4
 |                             pounds per 1000 cfm of rated gas flow capacity.  Prefliters
 B                             are definitely recommended 1f the particulate loading
 ™                             1s greater than 50 nrfcrograms per cubic meter.

 •                             Particles having a fibre or flake form are capable of
 •    *                        Inducing rapid clogging of a HEPA filter.

 _    ]                                5.  Beryllium Machine Shops

      j                                Figures 1 through 5 Illustrate some of the
 •   1                        emission controls.
      i
      !
      Ii
      ;                        Finish cutting and grinding operations produce more and
 «                             finer particulates than rough cutting.  Open face hood
                               velocities usually range from 150 to 300 fpm.  Dust
 •   j                          and chip capture velocities range from 500 to 3000 fpm.
                               Transport velocities are usually 3000 to 4000 fpm.
                                       6.  Foundries
 *   '                                 Gas fired lancing forms excessive fumes.  One
 •   i                         foundry control 1s shown 1n Figure 6.
     \
 •   i                          The evaluator should check emission controls for finishing
                               operations, which are dusty, and Involve cutting, grinding
i   i
                               and buffing.  Fabric filter installations have bags with

I
                                                        25
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air flow permeabilities 1n the range of 15 to 25 cfm/sq ft
and have been successfully operated at filter face
velocities of about 2 ft/m1n 1n beryllium - copper foundries.
The filter vendor's recommendations should be noted.

     7.  Beryllium Oxide Ceramics

     Controls useful 1n ceramic plants are shown in
Figure 7 and 8.  Such plants generate considerable submicron
partlculates.
                         26
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I
!
GUIDELINES FOR WAIVERS OF EMISSION
 TESTING IN FACILITIES INVOLVING
             MERCURY
                           I.   Introduction
                           These  guidelines  cover  requirements  necessary to qualify  for
                           a waiver of emission  testing  for mercury  extraction  facilities
                                                                                •
                           and facilities  using  mercury  chlor-alkali cells to produce
                           chlorine gas and  alkali metal  hydroxide,

                               A.   Mercury  Emission  Limit
                               According  to Section  61.52,, Subpart  E,  of the National
                           Emission Standards tor  Hdiardoub Air FulluiauLA, i,ul«u merCur v
                           emissions to the  atmosphere from a source must be limited to  a
                           maximum  of 2300 grams in a 24-hour period.   This limitation applies
                           to  the stack gas  emissions from mercury extraction facilities
                           and the  combined  hydrogen  stream, end-box ventilation  stream,
                           and cell-room emissions from  chlor-alkali facilities using mercury
                           cells.  Sources subject to the mercury standard must ver'f? their
                           compliance by conducting periodic emission  tests,  Section 61 ..53
                           of  the National Emission Standard for Hazardous Air  Pollutants
                           includes provisions for the initial  and periodic testing  of
                           both types of affected  facilities.

                               B.   Waiver of Emission Tests
                               Emission tests - initial, periodic or  both - may be
                           waived upon written application to the Administrator,  if  in his
                                                     1
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 Judgement the  source  1s meeting  the applicable emission limit
 or 1f the source  1s operating  under a waiver of compliance.
 Sources  not meeting the requirements of  II(a) may apply for a
 waiver of emission testing.  The decision  on whether or not to
 grant the waiver  will  be  based on the amount of material processed,
 the type of operation, the  type  of control  system Installed,
 and special factors pertinent  to that source.
II.  General Waiver Qualifications

 The following  requirements  are necessary to qualify for a
 waiver of emission testing  under Section 61.13 of the  National
 Emission Standard for Hazardous  Air Pollutants.
      A.   Mercury  extraction facilities which are either retort
      operations producing 2  .^sks of mercury per day  or less
      or  directly  heated operations with  capacities of  20 tons
      of  mercury ore per day or less will automatically be  granted
      a waiver  of  both initial  and periodic emission testing.
      B.   Sources  not  qualifying  for an automatic waiver of
      testing under  II(A)  must  be controlled so that the total
      effluents emitted to the  atmosphere do not contain more
      than 23QO grams  of mercury  per 24-hour period.

      C.   Control  equipment  and operation thereof must  be correctly
      represented  in  the waiver request application  and must continue
      to  exist and be  operated  as was  represented.   If  source
      test results were submitted with the waiver application,
      collection  efficiencies should equal or  exceed  those  claimed
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 I

 I
                                  |1n the application.
                                                 ,    ,   ..    -
 _                               D'.  Owners  or operators 'of facilities  employing mercury
                                  chlor-alkall  cells may demonstrate  compliance with  the
 8                               cell  room ventilation  portion  of the allowable emissions
                                  by applying the following  design, maintenance, and  house-
 I                               keeping practices  specified by the  Administrator.   Initial
 •*                               and periodic  source  test requirements  applying to the cell
                                  room will then be  waived.   A- value  of  1300 grams of mercury
 I                               per day will  be assigned to the cell-room emissions.

 •                                    (a)  Chlorine cells and end-box covers should  be
                                       Installed, operated,  and  maintained in a manner to
 •'                                    minimize leakagt  of mercury and mercury-contaminated
                                       materials.

                                       (b)  Daily inspection should be made by operating
 |                                     personnel to  detect leaks, and Immediate  steps to
 _                                     stop the leaks  should be  taken.
                                       (c)  High housekeeping standards  should be  enforced
 •                                     and any spills  of mercury should  be prompt!:  cleaned
 •                                     up either mechanically or chemically, or  by other
                                       appropriate means.   Each  cell  room facility should
 •                                     have available and  should employ  a well -defined
                                       procedure for handling these situations.

                                       (d)  Floor seams  should be smoothed over  to minimize
«
                                       depressions and to facilitate washing down of the
                                       floors.
-------
(e)  All floors should be maintained  in  good  condition,



free of cracking and spall ing,  and should  be»regularly



Inspected, cleaned, and to the  extent practical,  chemically
                                           •


decontaminated.
                                        •




(f)  Gaskets on denuders and hydrogen piping  should  be



maintained 1n good condition.  Daily  inspection  should



be made to detect hydrogen leaks and  prompt Corrective



action taken.  Covers on decomposers, end-boxes,  and



mercury pump tanks should be well maintained  and  kept


closed at all times except when operation requires




opening.





(g)  Precautions should le taken to avoid all mercury



spills when changing graphite grids or balls  in  horizontal



decomposers or graphite packinq in vertical decomposers.



Mercury-contaminated graphite should  be stored in closed



containers or under water or chemically treated  solutions



until it is processed for reuse or disposal.





(h)  Where submerged pumps are used for recycling



mercury from the decomposer to the inlet of the chlorine



cell, the mercury should be covered with an aqueous



layer maintained at a temperature below Its boiling point.





(i)  Each submerged pump  should have a vapor outlet with



a connection to the end-box ventilation system.  The



connection should be under a slight negative pressure



so that all vapors flow  into the  end-box ventilation  system.
-------
(j)  Unless' vapor tfght covers are provided, end-boxes
           •    »  •  •
of both Inlet and outlet ends of chlorine cells should
   *               i  •
be maintained under  an aqueous layer maintained at a
temperature below Us  boiling point.

(k*)  End boxes df cells should either be maintained under
a negative pressure  by a ventilation system or should be
equipped with fixed  covers which are leak tight.  The
ventilation system or end box covers should be maintained
1n good condition.
(1)  Any drips from hydrogen seal pots and compressor
seals should be collected and confined for processing
      •
to remove mercurv, and these drips should not be allowed
to run on the floor or in open trenches.

(m)  Solids and liquids collected from back-flushing
the filter used for alkali metal hydroxide should be
collected in an enclosed system.
(n)  Impure amalgam removed from cells and mercury
recovered from process systems should be stored  r> an
enclosed system.

(o)  Brine should not be purged to the cell room floor.
Headers or trenches should be provided when it Is
necessary to purge brine from the process.  Purged brine
should be returned to the system or sent to a treating
system to remove Its mercury content.
-------
            (p)   A  portable  tank should be used to collect any
            mercury spills during maintenance  procedures.
            (q)   Good maintenance practice should be followed
            when  cleaning chlorine  cells.  All cells when cleaned
            should  have  any  mercury surface covered continuously
            with  an aqueous  medium.   When the  cells are
            disassembled for overhaul maintenance, the bed plate
            should  be either decontaminated chemically or thoroughly
            flushed with water.

            (r)   Brine,  alkali metal  hydroxide, and water-wash
            process lines and pumps should be  maintained in  good
            condition, and leaks should be minimized.  Lea!;:;
            should  be collected  n  -u1table containers rather than
            allowed to spill on  floor areas.

III.  Required Information for Waiver of  Emission Testing
  The following  process  data and Information concerning  the
  mercury control systems with which the  facility  is attempting  to
  qualify for a  waiver must  be supplied with the waiver  application.

       A.  Process  Information

           1.  Complete  flow diagrams of  all operations  contributing
           to emissions.  Include mpteHal balances.
           2.  Estimated flow rate, composition, temperature,
           and other pertinent information on  atmospheric  emissions.
-------
I
I
                                    3.  Location and number of emission points.
                                    4.  Operations considered to be the major soyrces
                                    of emissions.
                                                                               •
                                    5.  Process calculations having any bearing on emissions
                                    and emission rates.
                                    6.  Effects of startup, shutdown, and abnormal operation
                                    on emission rates.  Description of process instrumentation
                                    designed to correct overloads or failures.
                                 B.  Control Equipment  Information
                                    1.  Engineering design calculations, Including
                                    assumptions, operation principle, and operating variables
                                    affecting performance and efficiency.
                                    2.  Manufacturer and model number.
                                    3.  Equipment specifications, include:  design capacity,
                                    guaranteed efficiency, performance data, and operating
                                    Instructions.  Include, where applicable, Info-nation
                                    such as:  allowable pressure drop, gas velocity, temperature,
                                    particulate loading, etc.
                                    4.  Equipment drawings.

                                    5.  Engineering drawings of control equipment as installed;
                                    with ducts, hoods, fans, piping and other auxiliaries.
-------
          6.   Spare  parts  required.

          7.   Scheduled maintenance  procedures.

      C.   Source  Test  for  Emissions
      If  requested,  the results  of an emission test  performed
 according to EPA -  approved  sampling and  analytical  techniques
 published with the  standard  must be included  1n  the waiver
 application.  All reports should Include  the  name and  telephone
 number of a  company representative  who  can  be contacted  to
 clarify  any  information submitted.

IV.  General  Maintenance and  Inspection  Procedure

 The following general maintenance and  inspection procedures
 are suggested for those sources applying  or qualifying for a
 waiver of emission  testing.
      A.   All maintenance  and Inspection requirements cited by
      the manufacturer of  the subject control  equipment should be
      strictly adhered to  with the exception of  those that require
      fewer inspections to be performed  than cited 1n this document,

      B.   If  the good  housekeeping option  is used to demonstrate
      compliance with  the  cell room  ventilation  portion of the
      allowable emissions  from a chlor-alkali  facility, the maintenance
      and inspection procedure discussed on  pages 3-6 must be followed.
      C.  Upon determination of any unsatisfactory conditions,
      corrective action should be taken.  In order to avoid excessive
                             8
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         emissions and/or loss of operating time,  a  supply

         of spare parts should be maintained.   Control  equipment
                                                    t
         manufacturers can provide recommendations as  to which
                                                  •
         parts should be kept on hand.


V.  Evaluation of Information Submitted with Testing Waiver

    Application
                                                      •

The sources meeting the requirements of II(A)  or II(D)  should be

automatically granted a waiver of emission testing.   When evaluating

the application of sources not qualifying for an automatic waiver,

the examiner must be convinced that mercury emissions  have been

or will be kept within the allowable Urit (2300 grams per ^-nour

period).  The safest course is to base  any decision  upon actual

source test results submitted with the  waiver application.  In

this case, the examiner must convince himself that the data are

truly representative and not accidentally low.


The Information received with an emission testing waiver application

should be evaluated by an experienced engineer.  This can t,<

performed in as much detail as manpower will allow,  consistent

with the number and complexity of emission points and control

devices.  As a minimum, the examiner should compare  the gas flow

rates, temperatures, and mercury concentrations with the values

listed in the vendors specifications and use the estimated collection

efficiencies of the control equipment to calculate an approximate

emission rate.
-------
The condenser gas stream is the major source of emissions
from a mercury extraction facility.   Appropriate control  techniques
Include cooling and mist elimination, wet scrubbing, er absorption
beds.  Major emissions of mercury from chlor-alkali- plants  using
mercury cells are from the hydrogen  gas stream, the end-box
ventilation stream, and the cell room ventilation air.   Emissions
from the hydrogen gas and the end-box ventilation air streams
can be controlled by cooling and mist elimination, chemical
scrubbing, or adsorption beds.  No techniques are presently
available to control the cell room ventilation air.  The control
of emissions from this source is dependent upon the application
of the good housekeeping practices presented in Section II  of  this
document.

The following general comments "^xr-ning control techniques
may act as a guide to the waiver evaluator.

     A.  Cooling and Condensing
     The cooling of a gas stream containing mercury vapo** below
Its mercury saturation temperature will cause the vapor to
condense, thereby reducing the mercury content of the gas.
Cooling can be accomplished by the use of either direct or
Indirect cooling techniques.  Because of the large particulate
loading of several of the process gas streams, direct cooling
methods may possess an advantage over indirect methods since
direct cooling would aid 1n mist and particulate removal.  The
use of direct cooling, however, would also introduce the
                            10
-------
I
                           necessity of water treatment facilities and create the possibility
                           of a water pollution problem.
                           In order to be effective as a control technique, cooling should
                           be followed by some type of mist elimination device.

                                B.  Mist Elimination
                                There are two basic types of mist eliminators commercially
                           available to remove mercury mist from process gas streams.  One
                           of these consists of a fiber bed, equipped with water sprays,
                           that removes the entrained mist by the mechanisms of impaction,
                           Interception, and Brownian movement.  A high particulate loading
                           (of contaminants other than mercury) may cause the efficiency of
                           this device tc be Icv/cr 1 ^n normal.  L'3c of additional flushing
                           water within the mist eliminator or installation of air precleaning
                           equipment prior to the mist eliminator may effectively solve the
                           problem.  The particulate mercury removal efficiency of this
                           type of mist elimination device has been estimated at 86 percent.
                           Another type of mist eliminator utilizes a coverglng - diverging
                           nozzle arranged so that the gases being cleaned follow o ,<'rved
                           path and are acted upon by high centrifugal forces in the
                           throat area.  These forces are reported to cause the coalescence
                           of mercury mist and entrapment of sub-micron mercury particulate
                           upon the upper wall of the divergent section.  This mist eliminator
                           1s reported to have an efficiency comparable to that of the fiber
                           pad type mist eliminator.

                                                       11
-------
     C,  Wet Scrubbing   •    •
     Wet scrubbing devices employ a variety of mechanisms
to collect particulate matter.  Interception of partlculate
matter by liquid dro'plets resulting In a heavier dust-liquid
                            •
agglomerate Is the most important of these mechanisms.  Particulate
matter collected on a liquid droplet in this manner can be
efficiently removed from the gas stream by a centrifugal  collector.
The particulate collection efficiencies of wet scrubbers vary
with energy input and can extend over a wide range depending on
the design.

The venturi scrubber is a high-energy, high efficiency scrubber
                •
that has been used to remove particulate matter from gas streams
             •
similar to the stack gas streams of mercury extraction facilities.
The water necessary to scrub a ,oOO SCFM gas stream is estimated
to be between 5 and 9 CPM, depending on the gas loading and
size distribution of the partlculate matter.  It is expected
that a particulate collection efficiency of 95 percent cc-jld be
achieved with a pressure drop of 20 to 30 inches of water through
the venturi and cyclone.
     D.  Chemical Scrubbing
         1.  Depleted Brine Scrubbing
         The depleted brine scrubbing technique uses the brine
         discharged from the chlorine cell as the scrubbing
         liquor.  This depleted brine contains about 250 grams
         per liter of sodium chloride and 0.6 to 0.9 grams per
                            12
-------
I
I
•                                    lit'er  of  available chlorine;  it has a pH of from 2
                                      to  4.   The  solution  is used as the scrubbing medium
                                      in  a sieve  plate  tower or  in  a packed bed scrubber.
M                                    Upon contact  with the brine scrubbing solution, the
                                      mercury vapor and mist form soluble mercury complexes.
                                      Mercury can be recovered by electrolysis when  the
                                      scrubbing medium  is  recycled  to the cell.  The exit
                                      mercury concentration of a hydrogen stream treated by
 H                                    this system has been reported to  be approximately 85
                                      micrograms  per cubic meter.
 •                                    2.  Hypochlorite  Scrubbing
 •                                    This system employs  a dilute  solution of sodium hypochlorite
                                      with a large  excess  of sodium chloride over the
 •                                    stoichiometric quantity.   The mercury removal  efficiency
                                      of  this system is maintained  over a wide enough pH range
 •                                    to  make control possible.  A  mercury collection efficiency
                                      of  95  to  99 percent  has been  reported.
                                  E.   Adsorption  Beds
                                      1.  Treated Activated Carbon
                                      Control systems containing either sulfur or iodine-
                                      impregnated activated carbon  are  being utilized by several
                                      chlor-alkali  facilities for reduction of the mercury
                                      concentration in  the hydrogen stream.  In these systems,
                                      the mercury vapor is adsorbed by  the carbon and chemically

                                                        13
-------
reacts with 'the iulfur of Iodine to form mercury
    *               *  *
compounds.  Some problems could arise 1f substantial
amounts of particulate mercury are present In the gas
stream; however, this situation could be corrected by
                   •
   •              t
either preheating the gas stream or by using a mist
elimination device prior to the carbon bed.

In order for treated activated carbon to perform
efficiently, the gas stream velocity through the bed
should be In the range of 20 to 40 feet per minute.
This low gas velocity is required to allow sufficient
contact^time between the mercury and the treated carbon.
A mercury vapor collection efficiency of approximately
90 percent is expected.  Destructive distillation of
the spent carbon appears practical for recovering the
adsorbed mercury.

2.  Molecular Sieve
The molecular sieve control technique utilizes a sieve-
adsorbent blend to adsorb the mercury contained in the
gas stream.  A molecular sieve system currently available
for the treatment of both the hydrogen gas and the end-box
ventilation streams of chlor-alkali plants  is  the
PuraSiv - Hg  System.  The designer of this system
guarantees a reduction of the mercury concentration to
0.50 milligrams per cubic meter.
                     14
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I                                                     ..
i                                  ••;•'.-
                                              i
I                                   GUIDELINES  FOR' WAIVERS OF
                                •COMPLIANCE WITH  EMISSION STANDARDS
_                                         FOR BERYLLIUM

_                        I.   Introduction
•                            1.  Legal Basis for Waivers of Compliance.
•                            According to Section 61.10 of Subpart A of the National
 |                         Emission  Standards for  Hazardous Pollutants, the operator of
|                        an  existing stationary source unable to operate 1n compliance
_                        with the  standard prescribed under Subpart C may request a waiver
™                        of  compliance with such standard.  Therefore, a plant  that is
•                        operating (including plants that are starting up) at the time the
                          NESHAP  1s promulgated and that is a source category covered by the
£                        «t»»tri;irri  should be eliaible for a waiver of compliance.  Plants
f                          not 1n  operation on the date of promulgation should not be
••                        granted waivers of compliance.  An eligible plant may  apply to EPA
1M                        for a compliance waiver by presenting the information  required by
                          Section 61.10 of NESHAP.  Presentation of complete and necessary
I                          Information is the operator's responsibility and should be done
.
 _                        with his  first transmittal of Information, drawings, and data.
 ™                        It  1s particularly important for him to be concise on  his ^ onosal
 fl                        for emission controls and on the timetable for their accomplishment,
 ^
 m                       II.   Guidelines to Length of Waivers
                              According to Section 61.11 of NESHAP, the Administrator may
 •                       grant a waiver of compliance with the beryllium emission standard
                          for a period not exceeding tv/o years.
 I
-------
      The  request  for  a waiver of compliance should Include the
                                                 >
  listing  of certain milestone dates  1n  a  plant's effort to achieve
  compliance.  The persons  1r EPA evaluating a waiver request should
  use the  information  presented  1n  Section III as a guideline to
  determine the length of the waiver.   It  is suggested  that the
  milestone guidelines be used as follows:
      A)  If the owner's  or operator's  requested lead time is  .
  less than the EPA guideline time, allow  a waiver time equal to
                                                       •
  the operator's requested  lead  time.
      B)  If the owner's  or operator's  requested lead time exceeds
  the EPA  guideline time  by up to 20  percent,  allow a waiver time
  equal  to the operator's requested lead time.
      C)  If the owner's  or operator's  requested time exceeds the
  EPA guideline value  over  20 percent.,  justification must be
  supplied for this longer  milestone  time  or the EPA milestone
  lead tire? will be granted.

III.  Derivation of Allowable Waiver  Lengths
      1.  Operations  Involved  in Emission  Control.
      Table I shows a  typical  sequence  of  ooerations  Involved  in
  the design and construction of any  sizable emission control  equip-
  ment.  Major activities are  Included; many minor  ones are  omitted.
  If a simple item like  a small  cyclone were  the only one  installed,
  many of  the 23 listed  operations  would not be  involved.   The most
  complex  case  would  involve large baghouses with new  fans and
  ductwork.
-------
, i
 4

i
       TABLE I.  SEQUENCE OF OPERATIONS IN
   DESIGN AND CONSTRUCTION OF BERYLLIUM EMISSION
                CONTROL EQUIPMENT.
 1.  Process design and flow diagram.              • ^
 2.  Engineering flow diagram and preliminary plot plans.
 3.  Specification and procurement of major items such as  fans
     and baghouse.
 4.  Specification of minor items, obtainable without complete
                                                      i
     drawings.
 5.  Design of electrical starters, switch-gear and distribution system,
 6.  Duct and piping arrangements and specifications.
 7.  Foundation design.
 8.  Structural steel design.
 9.  Receipt of certified dimension drawings of fans,  baghouse, etc.
10.  Release of foundation and structural  steel drawings.
11.  Start construction.
12.  Complete pipe and ductwork takeoffs,  and drawings for field support
13.  Release drawings and material listings for construction.
14.  Complete underground installations.
15.  Complete foundations.
16.  Delivery of structural steel and major items of equipment.
17.  Erect major items.
18.  Install ductwork and piping.
19.  Install electrical.
20.  Install instrumentation.
21.  Startup
22.  Source testing and analytical.
23.  Final report.
                               3
-------
    Table I shows that, 1n general, design continues Into
procurement and Into the early part of construction.  Nor can
                                                     >
design be complete until receipt of certified drawings;  which
presupposes that equipment purchase orders have been'placed
sometime before.  In short, many operations necessarily  overlap.
Thus, the waiver evaluator should be an experienced engineer
who can deal with the real complexities of plant design  and
scheduling; and - if at all possible - each waiver application
should be dealt with on a case by case basis.  Only for  a simple
retrofit is it possible to generalize on project timing  with
very much confidence.

    2.  Time Requirements for Construction and Startup.
    Table 2 gives the approximate lead times required for
fabrication, installation and startup of the equipment and
accessories likely to be Involved 1n retrofitting a plant
handling beryllium.
-------
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-------
    Fabrication lead times  are  Influenced  by many  things,  Including
size of equipment, materials  of construction,  general and  specific
                                                    »
level of construction activity, condition  of war or  peace,  foreign
and domestic labor trouble, government  policies, and so  on.  This
1s largely because of the effects  of the above upon  materials
and labor availability.   For  Instance,  foreign expropriation of
U. S, - owned copper mines  can  cause delays  1n delivery  of
electrical equipment.  A condition of war  tends to Increase
delivery time for all non-military Items.  The waiver evaluator
should make his own check on  Table 2 lead  times, especially 1f any
of the Items are large and  costly, or 1f strategic iretals  like
copper, nickel or chromium  are  Involved.

    3.  Events Required for Meeting Emission Standards.
    A waiver request can be granted for up to  2 years, but the
actual waiver time allowance  should only be  that required  to
design, install, startup, test  and prove the performance of
suitable control equipment.  For this overall  objective, a
number of events must take  place,  or a  number  of milestones have
to be met.  Table 3 Illustrates these events or milestones of
emission control progress.   The reader should  note the  range
of time requirements.  Table  3 fits no actual  case.   If one
package control item only were involved, events could tend to
be consecutive:  thus, ordering could follow grant of waiver,
Installation would follow procurement, startup follow installation,
etc.  In the more general case of more than  one control, with
-------
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-------
each control requiring fabrication, no simple sequence of
consecutive events 1s possible.  Instead, the events overlap
1n a manner which requires case - by - case study.   Thus, the
wise operator will begin engineering design before  he submits
                           t
his waiver application; and some design work must continue
during equipment fabrication and sometimes even continue Into
the Installation period.  Fabrication starts as early as possible
on Items needed early; they may be installed while  other items
are still being fabricated.

    It 1s clear that the total time requirements suggested by
Table 3 apply to only a complex case, such as 1f a  beryllium
extraction facility were suddenly to require emission controls
throughout (a hypothetical case).  Early initiation of an activity
tends to be controlling (such as a quick start on bids and
fabrication).  The lengthening of an activity (like engineering
design) is only important to the degree that 1t can lengthen the
overall time schedule.  Startup, of course, must follow installation
without overlap.  However, report writing can be partly done
before completion of source testing.
    Line lengths on Table 3 indicate 5 month ranges for fabrication
and installation.  But two 5 - month Items could require a
longer total fabrication time if not started simultaneously.
In other words, the total times for fabrication or installation of
all Items could be considerably more than 5 months, depending
upon proper project management.
-------
                                                         t

                                                               I
I
•                             4.   Compliance Wa(1ver,T1mq Requirements.
•                             The derivation of allowable  waiver  time  1s  best represented
 1                          by specific examples.  Consider  an  operation  currently  having
P                         bag filters.  To Insure that beryllium  emissions  will be
^                         maintained below the lega> fimits,  a HEPA filter  will be  added.
*                         Its operating pressure drop will be low enouqh  to require no
ft                         additional fan capacity, and additional  ductwork  will be  minimal.
 ]                          This, then, 1s a simple case of  addition of  one equipment piece
0                         without significant auxiliaries. The derivation  of allowable
—                         waiver tiire is given in Table 4  and the total waiver time 1s
*                         the sum of Items in the last column of  that  table.  The total
ft                         allowable waiver, time is therefore  302  days  after grant of
                           v/aiver, assuming ordering activity  started at time of waiver
ft                         grant.

I                             In  Table 4, filter ordering  includes writing  specifications,
                           getting and comparing bids, and  placing an order.  Filter delivery
P                         Includes fabrication and assembly,  shipping  and delivery  to
 •                         jobs He.
 M                             Note that the waiver evaluator  must feel  that the HEPA
^                         filter addition will be an Improvement  and will do the  job;
 i
ft                         otherwise he would refuse the waiver.
 to                             Waiver evaluations for more  complex situations can  be treated
                           by a similar method, with exceptions as pointed out below.  Consider
 I                         a beryllium oxide ceramic plant  which must add  control  equipment
                           to a certain operation.  The flow 1s 10,000  cfm and a baghouse
 I
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                          must be  added.  This baghouse must be proceeded by a cyclone
                          separator.  Also, because of a wide particle size distribution,
                          a HEPA 1s advisable to remove part of the fines that escape the
                          baghouse.
                              Referring to Table 2, this case clearly involves design
                          and Installation of all of the equipment shown in the table,
                          including fan and extensive ductwork.  One could therefore make
                          five tables (like table 4) to cover the five major items of
                          work.  If we assume that design, procurement, and Installation
                          could proceed independently for each item/1.e. for baghouse,
                          fan, etc) the time to startup would just be the latest time shovm
                          among the five  items.
                              For  Instance, from table 2, the time for fabrication and
                          deliveries to the job site are:
                              cyclones              164 days
Im                            baghouse              164 days
,                              HEPA filter          164 days
jl                            fan                    98 days
!                              ductwork               74 days
!•                        and this part of the job would consume 164 days if all orders
i
•                        were placed simultaneously.  This can seldom happen, due to
                          manpower limitations and it 1s less likely to happen as the
I                        number of items increases.

•                            The  waiver  evaluation for addition of controls to the ceramic
                          plant is shown  in Table 5.  Time starts at arant of waiver.
I

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                            Procurement work was started first on the baahouse.   It Is
                            assumed that the staff 1s not large enouqh to start  on all
                            Items simultaneously, but that some work can be done on the
                            HEPA after 20 days, on the cyclone after 30 and on the fan  after
                            40.  The ductwork can be done right along, due to previous  work
                            on engineering and to the simple specifications.

                                Other appropriate time requirements are added to Table  5
                            from Table 2.  The on-site time for the various Items is
                            shown.  Ductwork is available when other Items arrive.  Some
                            of it can be installed after the fan arrives, most of it when
                            the baghouse is set up, and all of it wnen the HEPA  is in place.
                            In other v/ords, all ductwork can be installed within about  150
                            days of 244 + 30 days (Hi.A column, table 5).  However, we  will
                            start installation when the fan is positioned, after say, 197
                            days.  Our time schedule will be as shown in table 6 and will
                            be the total waiver time.  Table 6 corresponds to column 3  in
                            table 4 for the simple case.  The other missing columns may
                            readily be derived for the ceramic plant, to make a  table like
                            table 4.
                                                     13
-------
   TABLE 6  TOTAL WAIVER TIME FOR CERAMIC PLANT
                                                    »
Procurement                     85 days          '  .•
Delivery                        98_
     on site time              183
Installation, fan               14
Installation, ductwork         150
                                                    •
Startup                         14
Source sampling & analysis      40
Final report                    30

Total waiver time              431 days

     Table 5 assumes one source sampling team, starting on the
HEPA exit and then moving to the baghouse.  A less  conservative
waiver time would assume ductwork Installation time to
commence upon positioning of the baghouse (I.e.  224 + 30 •»• 150
etc. days) for a total waiver time of 508 days.
     A second method of estimating total waiver time for the
above beryllium ceramic plant v/ould Involve the use of critical
path techniques.  To do this, one needs to 11st all of the tasks
Involved, from grant of waiver to final report.  The time required
to perform each task Is then carefully determined and listed.
Secondly, the necessary and sufficient predecessor of each task
1s determined.  In general, this will lead to two or more parallel
lines of tasks, or chains of milestones or events.   In general, also,
                           14
-------
the time required to perform'each of these  lines of  tasks will
differ.  The longest time path will be the  allowable waiver  time,
to be modified as shov/n in table 4.  This critical path  technique  1s
well known and 1s explained  in numerous reference v/orks.
                       15
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•T

I
 I
 I
                                         GUIDELINES FOR WAIVERS OF
                                    COMPLIANCE WITH EMISSION STANDARDS
                                                FOR MERCURY
 I.   Introduction
     1,   Legal  Basis for Waivers of Compliance.
     According  to Section 61.10 of Subpart A of the National
 Emission Standards for Hazardous Pollutants, the operator of
 an  existing stationary source unable to operate in compliance
 with the standard prescribed under Subpart C may request a waiver
 of  compliance  with such standard.  Therefore, a plant that is
 operating (including plants trvc are starting up) at the time  the
 NESHAP  is promulgated and that is a source category covered bv the
 standard shou'M be eligible *'-.r a waiver of compliance.  Plants
 not in  or>frai (..  >    thr  '       ,•*  'MS!Cation should not be
 grant's; •. -  ,          e plant may apply to EPA
 frr a -ro", i  -.      -. i-:f f'V ,-        •  '"e ^formation requ*"rnd hv
 Section 61,;.    '  -{ SHAIJ,  Prt--    :.L:,i-  ./f complete and nec'lssarv
 information i':   t'-- operator'j r-\^- n•-• ^H ny and should be dr ie
 v/ith his ?ir-i'   ,.<• I'ssmittal of infom-.f>on, drawings, a°d data.
 It  is part:, .• <     > important ^or film to tie concise oo his proposal
 for en• ••.,.••'^ f-n.if;>is and on the timetable for their ac^.    ishment.
II.   Guidelines  to Length of fivers
     According  to Section 61.11 of NESHAP, the Administrator may
 grant a waiver of compliance with the mercury emission standard
 for a period not exceeding two vt^r^.
-------
      The  request  for a waiver of compliance should Include the
  listing  of  certain milestone dates  in a plant's effort to achiove
  compliance.  The persons  in EPA evaluating a v/aiver request should
  use  the  information presented  in  Section  III as a guideline to
  determine the  length of the waiver.   It is suggested  that the
  milestone guidelines he used as follows:
      A)   If  the owner's or operator's  requested lead time is
  less than the  EPA guideline time, allow a waiver time equal to
  the  operator's requested  lead  time.
      B)   If  the owner's or operator's  requested lead time exceeds
  the  EPA  guideline time by up to 20  percent, allow a waiver  time
  equal  to the operator's requested lead time.
      C)   If  the ov/ner's or operator's  requested time exceeds the
  EPA  guideline  value over  20 percent,  justification must be
  supplied for this longer  mllesx^ie  time or the EPA milestone
  leau ti>e v, 11 be granted.

Ill,   Derivation of Allowable Waiver  Lengths
      1.   Operations  Involved  in Emission Control.
      Table  I shows a  typical sequence  of operations  involved in
  the  design  and construction of any  sizable emission control equip-
  ment.  Major activities are  included; many minor  ones are  omitt; >.
  If a simple item like  a mist eliminator were  the  only one  installed,
  many of the 23 listed  operations  would not be involved.   The  more
  complex cases  would  involve  such  items  as chemical  scrubbers, or
  cell room modifications.
-------
         TABLE  I.   SEQUENCE OF  OPERATIONS IN
      DESIGN  AND CONSTRUCTION OF M
                     CONTROL EQUIPMENT,
 1.  Process  design and flow  ••;   --i!i»
 2.  Engineer ;.'(=., !•;..* diagram *•..'< rn i •• inary  plot plans,
 3.  SpecifH;atiu!\ and procurnM->.>  c,' rvjor  Items  such as molecular
                                 'if ,  'i» t-innablf1 without complete
 5,
                                                         siribution  system.
 /,  f< •;:' 1ft! '•• :  ...-
 B   H ?''»; ; i ' - '
1 !    '   .  ' ,
12    •''• •  I.  .-  ,
     - ; , t  J ..    •'
"4,  < :•', i  l-r>
                                                   i«-  n  equipment.
                                                '   ;"  ;i.'' '  '-;" .
                                                          ^or field  supnnrt
22
-------
    Table  I  shows that,  in qcneral,  de/nn conn rues  Into
procurement  and Into  the eurly part  :. '       , .,,  , [on,   Nor can
design be  complete until  rerc^pt <">;  v      ;   '   . .-'V.incs.,  which
presupposes  that equipment purchase  :-\ <•••.-,—, • %-c- been  placed
some time  before.  In  short, many operations necessarily overlap.
Thus,  the  waiver evaU'a*^'" should b.? ;>n exr^r- -:nrecl engineer
who can  deal with  *•  '  <•  ;': r  ::plexit <;    • "•'; •  *  .-ipv;..-  ^r»H
schedul inri;  •••          ••.,'-,:,                ,   A-^ *  •_•••••
should be  k   ,-.;•'.;•  .         , -,          .      , .   , <  ^ -^inple
retrofit is  u po-.^  ->  -  !    • ,-• •   M .-               '.lining  with very
much confidence,
         2"| - r  . >  *~s t ,  *.  -  - s ,
     t   I ' E c,  \ u «                                    ,-
    Table  ."  -;' - -r:  ;  -          \ •  •              •      .  1 'or
fabricatic   .    :•.•  . •            .                    •.••, ^'i
ce '< .     \  fM- j o«"ii,i;irv   .    ,, » riro^i     ,         :.••'_.   It;;'t,  15
17  in1- o-vt process  chap     ...;ic,- cov. -•  x   ••    -  •  ..-^ ,,
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•                                 Fabrication  lead times are Influenced by  many things, Including
•                           size  of equipment, materials of construction,  general  and specific
                             level  of construction activity, r (•••-> <.i if ion of war or peace, foreign
|                           and domestic  labor trouble,  -      ^enr policies, and  so  on.  This
—                           is largely b-f,.  .   ,,, tiiL  !•-'•  •,-.  -..:   ••  dbove t-p'^n materials
™
                             and  lafior ,-\\-.\ •;•   "?•;    Kn   ,  •:•••(•, rire <<'r-.  -• > ;>r(V:riation of
•                           U, S.    <'M,vJ  •  p; • r  'tis.-'S  t.u. , :.,••.'  ;i,'"i',  "  .  ,s • ".  ' ii"da"ds.
                                   A v/aiv'-"   - •• r -- t,r'» :    ^r.-M'.eci  f,;  jp  tr;  ? years, but the
•                           actua"  wa-V'.-;  *•.:<•    ! ••'•'.,            ,;,-s on)v  ;>t'  <.f-af f'Vouired to
                             •ic: ; v  '•••••             '   -  -v •  • ;  -.   ' .-  ;.«r   -run ,re  of
•                           -' '                        -                          •• 7  >ft
tf|                           '•'?•>
                             tO be  li ."I ,                 '             •            . •• i--', ^.iriijS
 •                           emission coritrr     •  i'-ess,    •    -•.'•;.'?->   nns'Uf note the *anqe
                             of time  tt  ; ,-,  r-    ' *.,  fable  ';  f^r, no '*rtu-"«'! c.'.sA,   If one
 m                           pack?[-,-  ••  =-    •    -.   >>;'v i- r   '.- ,'•. •'/*-•.;,  rvent-s >;o,.nd  if  ,
 •j                           oe ee>r>-.'''.   . .  -        .     a-'  •••,   • ;u-  i i-  '.'.,    i "   o»  waiver,

 •                           etc,   ;«      -oir.      i^' c;    . •  -  •  tfi,
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each  control  ren.^rii>n  fabric.iri'in,  no :>4t-,ple scM(uencr» of

consecutive ;   :•< • \ \'- j<'.;ss1!'
in a  manne-r •,'••'••

wise  oper-s* •   •  '   . •••' ii  •*;-••
his wci^- -  -  -i .    ^- ;
on  iti-     ,-cii'Hi  f.'c-

are  i; '.'••} be in'-i  f«.
                             fa-

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".•   •   ••-••  ',-^orp hp  submits

^nies  ever, continue into

 i-..,)  sfar'.s     '1r-'i '  -a< possible

  • •  t-il ioci  .."i c*-- f:;>  - Hems
      It is clear  that tne  tot,     "^' t

Table  3 apply  to  '-hlv a  comp-e«,   •>.  t-,
mercur,  ex^'ar 1 \ --rs <   ^'            >  ,
                                           cul rrinonts suggested  by

                                            v »i  -'^  it" a  large primary

                                            ,   :   *rnt, ,  i-  emission

                                                 ',;<",  ir.  ': ' ,-^tHin  of an

                                               »  0-   '•  <,tr"-*t  r.p f-'^ls anil

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-------
     4.  Compliance  Waiver Time R<*;<-. •   '?ents,
     The derivation  of dUowablp     .?  s i no is best  represented
by specific exar-'ip-v,   .  certain ,,   «   r,-•  urv extraction
facility has o>-3l^ed  a new supplv t.t cola 'nountain v/ater v/hich
novi changes their mercury condenser ccoMnc water  temperature
from 78°F to a new  temperature of ro°(-.   This results in  increased
particulate me re urv  emission and they ""H>e$t a v/aiver during
installation of ^ T,err...>   ^ist el in incite-,  'Ms is a simnle case
of additi'-r. o""  ' -ir  . -\,
The derivation  of  a'• h
the total v.Mv--r u-:.-j
that table,   T» e •  '
after gram at  wa i ver
of waiver -   - •'. .
', a i vf-r
.mfirant auxiliaries.
 •""-  *!ri  "fable 4 and
.••!=•  ir-st column of
! •;  tnr-refore 271 days
• ly  star.ed at time
                           12
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     In Table  4, mist eliminator or<•"•'' :>
treated by a similar net hod, with e<    -
below.  Consider the folio M:  ;  •• mv»?  >t
a chlor-alkali  pl:»' -•>  •  ,:,jl(,      • >
plant will ,,,e  i >J;-;inicd!  •••-•'         r,
box vet'.t", ''^ -~>r. •• •   'i-       ' -  fi/fif. ,-<•'•,
                                                       can be
                                            -    -~  pointed out
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                                           i:\a  ;.i.indard.,  This
                                          .. ,- ;in  jioth the end
                                           v.  - ' *•  »r, to achieve
lov-e-/ ,r,  t-,t,  pla-it        .  - ;,5-.  ;   •
their end  boxes  and t*H- e  vn 1 ]  be cor, itr..;
and design work  sill     '•  ie  in-hou-.r
                                                   All  the engineering
     Referrinr t-.-. 'lat-i-   , ,  this  cas-; clearly  involves design
and co- v.t >":>••     -  '-> •     "   i:~., t      ^ -•   , ,a!  tank, scruhbor,
mist eliminator,. . •.  t ;-^   ,,-v. ?•-,„ _,>,. '>.-/:•.  ,j',j  Herhc.p> fan.  However,
it will  be assumed trial  (-.-•  addit'."'.--'!  ''>**••  ".  '"^lui^ed for
this job di.n auv n-^tde.:  ;  • ',. •-, ; 1 1 -e  ' ••"• •  '  ••! \/1th the scrubber.
One could  there"(,M,  HWK^  f^vt-  t-. i     • '     < ,• .. .  1; ti> cove,1
the five me   •        •           ':..•„  t, -   ^tsign, procurement
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_                         and Installation could proceed  independently for each item
'                         (I.e. for seal tank,  scrubber,  etc) the time to startup  would just
I                         be the latest time shown  among  tK< five items.
•                              For instance, from tabie \'.,  tne tme for fabrication and
                           deliveries to the job site  are-,
•                              scrubber                 1^4  days
                                mist eliminator          140  days
•                              end t\jx covers           74 days
•                         and this part of the  job  would  consume 194 days if all orders
                           were placed simultaneously,  This can seldom hanpen, due to
•                         manpower limitanoris  arid  it is  l- ss likely to happen as  the
                           number of items  increases,

                                The waive'   * valuation  f -:  addition of controls to the
|                         chlor-aikalie plant  is sf•       rable 5,  Time starts at grant
_                         ,>f wav-->! «  'fun-'o :     ,  Hrct  on  the chr--ri_,'i scrubber which

•                         .  •
™                              The r>(5,.'•  t-si--  is  a  ?.im> i-.- - ie.fi wMc1- : *.f-  i-o  >tarted at any
•                         reasonable  time,   If time  permits, the end bc,\ covers  should be
                           started eariy, because of  thnir relation to connections,,
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     Other  appropriate time requirements are added  to  table 5
from table  2,   The on-site time  for the various Items  is  shown.
All ductwork  and piping is avaiKl-le shortly before scrubber
arrival and sonic :"  t'vis v/oulc  ,  JDUUV ; .;• on rite  and installed
even e^  '  ;
                           exst  of  n
                           ThUS, O'u: « ?c.
wil! br  th-'  f
in  tabi column 3
   '; •    •<.-!• sin<; columns
 ;,<•  the chlor-alkalie
• >us  to table 4.

      1 ••*,  ;~  "-pducpd somevhat,

           •  • •  i.hc conservative


 otal  waiver"  time  for  lt;f
   •  '.'^:  :is-.- o* cr Hlcal
•-• ,-•>  !   *i    ,*  ! of the
     •"•.,'ui •   •.'r.-.r'f,  The  time

•   -j^Hient preaecessor  of
 I
                                                     17
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TABLE 6.  TOTAL WAIVER TIME FOR CHLOR-AlML IF  PLANT

  Procurement                            145  days
  Delivery                               JB£
       On site tine                      ~-'1r-
  Install at ion
  Startup
  Source sampling and analysis
  Final report
       Total  v/aiver t i;\e
                            18
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each task is determined.   In  general, this will lead to two
or more parallel  lines  of tasks,  or chains of milestones or events,
In general, also,  the time required to perform each of these
lines of tasks will differ.   The  longest time path will be the
allowable waiver  time,  to be  modified as shown in table 4.  This
critical path technique is well  known and is explained in
numerous reference works.
                                         ravi..'or.m T.r,:.I Protection Agency
                                         R-" ] -.  V,_ Jr.brery
                                         rc> i >...  .-h r>.;sr-bo'rn Street
                                         Cl—„, i/>D Illinois  6060«f
                         19
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