Chemical Industry Leadership Needed
Feb 1, 1998 12:00 PM, Charles E. Wilson
REPRESENTATIVES from the chemical, petroleum, and tank truck industries met with Environmental Protection Agency (EPA) officials in January in Atlanta, Georgia. The purpose of the meeting was to begin laying the groundwork for a new EPA regulation aimed at preventing the release of organic chemical vapors.
By all indications, the rule that emerges over the next couple of years will have a broad impact. It will affect any company involved in the production, transportation, storage, and use of the targeted products.
Besides meeting with industry representatives to outline basic objectives of the rulemaking, EPA officials are preparing a survey that will gather data on current vapor-handling procedures. The survey probably will be ready for distribution in late March or early April. Reportedly, the survey will focus on just chemical manufacturing. It will look at vapor handling procedures within the manufacturing processes and the sort of systems and hardware that are already in place. EPA wants to find out what is being done with chemical vapors at this point.
Site visits probably will follow at a later date. This is what EPA did during the early phases of the wash-water-effluent rulemaking. That program is reaching a conclusion, and a rule should be published any day now.
In the vapor-recovery rulemaking effort, EPA is charged with designing a cradle-to-grave procedure for eliminating, or at least controlling, emissions. Any rule probably will require implementation of systems that use maximum achievable control technology.
EPA may follow the same backdoor strategy that was used with Method 27 vapor-leak testing. Because the agency doesn't have transport jurisdiction, it charged loading racks with the responsibility of verifying that tank trucks comply with Method 27.
Chemical plants, loading racks, and receiver facilities may be made responsible for vapor recovery. In turn, they would have to ensure compliance by the tank trucks and tank containers that are operating through their facilities.
It's impossible to describe any specifics of the coming rule at this point. We know vapor recovery will be addressed, but we don't know if closed-loop loading and unloading will be mandated. We don't know how much EPA plans to mandate and how much discretion will be left to industry.
We don't know how issues such as vapor custody will be resolved. EPA hasn't even begun looking at such legal issues. When they do, they are likely to find that they have opened a can of worms.
We do have a pretty good idea of what the agency will find when it begins to study the vapor-emission-control issue in earnest. They will discover a chaotic situation that is totally lacking in uniformity.
The level of vapor recovery activity within the chemical industry ranges all over the board. Some of the most advanced control efforts can be found in places such as Houston, Texas, where strict vapor-emission limits have been in place for several years.
A multitude of vapor recovery systems are being used. Some plants have taken a proactive stance and have moved full force into closed-loop loading, while others haven't even taken a first step.
This lack of uniformity poses plenty of challenges for the tank truck carriers that serve the chemical industry. Tractor-trailer rigs must carry a variety of vapor-recovery fittings, and drivers sometimes must guess how to attach everything properly.
Mandatory vapor recovery is a certainty now. Even though a final rule is unlikely before 2000, it is coming. EPA deserves praise for holding these initial meetings with industry, and we hope that the agency will give fair consideration to any reasonable suggestions and recommendations.
It's also time for the chemical industry to develop the same sort of uniform standards that were adopted many years ago by the American Petroleum Institute (API). It should be noted that the API standard has been accep ted virtually worldwide.
This is an area where the chemical industry and its various associations should take a leadership role. Industry action may help moderate the EPA rule and make it more palatable.
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