National Emission Standards for Hazardous Air Pollutants; Proposed Standards for Hazardous Air Pollutant Emissions From Magnetic Tape Manufacturing Operations; Proposed Rule ENVIRONMENTAL PROTECTION AGENCY
Federal RegisterMar 11, 1994
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SUMMARY: The EPA is proposing standards that would limit emissions of
hazardous air pollutants (HAP) from existing and new magnetic tape
manufacturing operations that are part of major sources. The proposed
standards implement sections 112(d) and 112(h) of the Clean Air Act as
amended in 1990 (the Act), which requires the Administrator to regulate
emissions of HAP listed in section 112(b) of the Act. The intent of the
proposed standards is to protect the public by requiring new and
existing major sources to control emissions to the level corresponding
to the maximum achievable control technology (MACT), taking into
consideration the cost of achieving such emission reductions, any non-
air quality and other air quality-related health and environmental
impacts, and energy requirements.
DATES: Comments. Comments must be received on or before April 25, 1994.
Public Hearing. A public hearing will be held, if requested, to provide
interested persons an opportunity for oral presentation of data, views,
or arguments concerning the proposed standards for the magnetic tape
manufacturing industry. If anyone contacts the EPA requesting to speak
at a public hearing by April 5, 1994, a public hearing will be held on
April 13, 1994 beginning at 10 a.m. Persons interested in attending the
hearing should notify Ms. Julia Latta at (919) 541-5578 to verify that
a hearing will occur.
ADDRESSES: Comments. Comments should be submitted (in duplicate, if
possible) to: Air and Radiation Docket and Information Center,
Attention, Docket No. A-91-31, U. S. Environmental Protection Agency,
401 M Street, SW., Washington, DC 20460. The EPA requests that a
separate copy also be sent to the contact person listed below.
Public Hearing. If anyone contacts the EPA requesting a public
hearing, the hearing will be held at the EPA Office of Administration
Auditorium in Research Triangle Park, North Carolina. Persons wishing
to present oral testimony must contact the EPA by April 5, 1994 by
contacting Ms. Julia Latta, Standards Development Branch (MD-13), U. S.
Environmental Protection Agency, Research Triangle Park, North Carolina
27711, telephone number (919) 541-5578.
Background Information Document. The Background Information
Document (BID) for the proposed standards may be obtained from the
docket or from the U.S. EPA Library (MD-35), Research Triangle Park,
North Carolina 27711, telephone number (919) 541-2777. Please refer to,
``Hazardous Air Pollutants from Magnetic Tape Manufacturing--Background
Information for Proposed Standards,'' EPA-453/R-93-059.
Docket. Docket No. A-91-31, containing supporting information used
in developing the proposed standards, is available for public
inspection and copying between 8 a.m. and 4 p.m., Monday through
Friday, at the EPA's Air and Radiation Docket and Information Center,
Waterside Mall, room 1500, 1st Floor, 401 M Street, SW., Washington, DC
20460. Telephone (202) 260-7548. The proposed regulatory text and other
materials related to this rulemaking are available for review in the
docket. A reasonable fee may be charged for copying.
FOR FURTHER INFORMATION CONTACT: For information concerning regulatory
decisions and the proposed standards, contact Ms. Gail Lacy at (919)
541-5261, Standards Development Branch, Emissions Standards Division
(MD-13), U. S. Environmental Protection Agency, Research Triangle Park,
North Carolina 27711.
SUPPLEMENTARY INFORMATION: The information presented in this preamble
is organized as follows:
I. Summary of Proposed Standards.
A. Applicability of the Standards.
B. Actual Standards and Format of the Standards.
C. Monitoring Requirements.
D. Test Methods for Compliance.
E. Reporting and Recordkeeping Requirements.
II. List of Source Categories.
III. Background.
IV. Authority for National Emission Standards for Hazardous Air
Pollutants Decision Process.
A. Source of Authority for NESHAP Development.
B. Criteria for Development of NESHAP.
V. Summary of Environmental, Energy, Economic, and Cost Impacts.
A. Environmental Impacts.
B. Energy Impacts.
C. Economic Impacts.
D. Cost Impacts.
VI. Rationale.
A. Selection of Pollutant and Source Category for Control.
B. Selection of Emission Points.
C. Selection of Basis and Level of the Proposed Standards for
Existing Sources.
D. Selection of Basis and Level of the Proposed Standards for
New Sources.
E. Pollution Prevention Considerations.
F. Selection of Format.
G. Selection of Emission Limits, Work Practice, and Equipment
Standards.
H. Selection of Monitoring Requirements.
I. Selection of Compliance Test Methods.
J. Selection of Definition of Affected Source.
K. Selection of Reporting and Recordkeeping Requirements.
L. Applicability of the General Provisions.
VII. Administrative Requirements.
A. Public Hearing.
B. Docket.
C. Executive Order 12866.
D. Paperwork Reduction Act.
E. Regulatory Flexibility Act.
F. Miscellaneous.
G. Statutory Authority.
The proposed regulatory text is not included in this Federal
Register notice, but is available in Docket No. A-91-31 or by request
from the EPA contact persons designated earlier in this notice free of
charge. The proposed regulatory language is also available on the
Technology Transfer Network (TTN), one of EPA's electronic bulletin
boards. TTN provides information and technology exchange in various
areas of air pollution control. The service is free, except for the
cost of a phone call. Dial (919) 541-5742 for up to a 14,400 bps modem.
If more information on TTN is needed call the HELP line at (919) 541-
5384.
I. Summary of Proposed Standards
This section provides an overview of:
(1) The applicability of the standards;
(2) The format of the standards;
(3) The actual standards;
(4) The monitoring requirements;
(5) The test methods for compliance; and
(6) The reporting and recordkeeping requirements. Detailed
discussions concerning the statutory basis and the selection rationale
for the proposed standards are provided in sections IV and VI,
respectively, of this preamble.
A. Applicability of the Standards
The proposed standards apply to new and existing major sources
emitting HAP from magnetic tape manufacturing operations, according to
certain criteria. First, a source is subject to all of the provisions
of the standards if it is major, that is, if it has the potential to
emit greater than 9.1 Mg/yr (10 tons/yr) of any one HAP or 22.7 Mg/yr
(25 tons/yr) of any combination of HAP. Second, a major source actually
utilizing less than 9.1 Mg/yr (10 tons/yr) of any one HAP or 22.7 Mg/yr
(25 tons/yr) of any combination of HAP is subject only to an annual
recordkeeping and reporting requirement (Sec. 63.703(g)) of the
proposed rule. Finally, research or laboratory facilities are not
subject to the provisions of the standards unless they are collocated
with production lines.
Several solvent and particulate HAP are used in the magnetic tape
manufacturing industry. Solvent HAP used include methyl ethyl ketone
(MEK), toluene, methyl isobutyl ketone (MIBK), toluene diisocyanate,
ethylene glycol, methanol, xylenes, ethyl benzene, and acetaldehyde.
The HAP solvents that are used to the greatest extent are MEK, toluene,
and MIBK. The other HAP are used in small quantities at only a few
facilities in the source category. Chromium and cobalt, which are
particulate HAP, are also used. These are the HAP expected to be
emitted by this industry; however, the proposed standards apply to
emissions of all 189 HAP listed in section 112(b).
This standard covers HAP emission sources that result from magnetic
tape manufacturing operations. Products manufactured as a result of
these operations include video and audio tape, and computer diskettes.
Production of nonmagnetic products may require use of some of the same
equipment as is needed for magnetic products. For example, leader tape
is the tape at the beginning of an audio or video cassette that does
not contain magnetic media. Leader tape is manufactured on the same
type of equipment that is used to manufacture magnetic tape, and is
directly related to manufacturing operations. Therefore, the production
of leader tape is considered as part of magnetic tape manufacturing
operations.
Likewise, other products may be manufactured using the same
solvents and equipment that are used to coat the tape with magnetic
material. If HAP are used during their production, and the same
equipment that is used for manufacturing magnetic tape products is used
in their manufacture, the provisions of this standard apply when these
products are being manufactured.
Sources in a magnetic tape manufacturing operation that are
affected by the standards include but are not limited to:
(1) The solvent storage tanks;
(2) The mix preparation equipment;
(3) The coating operation;
(4) The waste handling devices;
(5) The particulate transfer operations;
(6) The wash sinks for cleaning removable parts;
(7) Cleaning involving the flushing of fixed lines;
(8) Wastewater treatment systems; and
(9) Condenser vents in the solvent recovery area except the vent on
a condenser that is used as the primary control device.
A description of the emission points within magnetic tape
manufacturing operations can be found in section VI.B.
B. Actual Standards and Format of the Standards
The proposed standards are expressed in terms of percent control of
HAP, as outlet concentrations of HAP, and as equipment standards for
the various emission points that comprise the magnetic tape operation.
A summary of the requirements of the proposed standards is provided in
table 1.
Table 1.--Summary of the Requirements of the Proposed Standards
------------------------------------------------------------------------
Emission point Standards
------------------------------------------------------------------------
Solvent storage tanks.............. 95-percent overall HAP control
efficiency.a, b
Mix preparation equipment.......... 95-percent overall HAP control
efficiency.a, b
Coating operation equipment........ 95-percent overall HAP control
efficiency.a, b
Waste handling devices............. 95-percent overall HAP control
efficiency.a, b
Condenser vents in solvent recovery 95-percent overall HAP control
efficiency.a, b
Wastewater treatment systems....... Remove 99 percent of the HAP in the
wastewater or achieve a total HAP
outlet concentration of 50 ppmw.
Wash sinks for cleaning removable 88-percent overall HAP control
parts. efficiency.
Particulate transfer devices....... Equipment standard--use enclosed
transfer device.
Cleaning involving the flushing of Equipment standard--use closed
fixed lines. system for flushing fixed lines or
vent open containers to a control
device.
------------------------------------------------------------------------
aThe overall control efficiency is the product of the capture efficiency
and the control efficiency.
bFor sources using incinerators as control devices an alternate emission
limit of 20 ppmv HAP is allowed.
As indicated in Table 1, the proposed standards require an overall
HAP control efficiency (the product of capture efficiency and control
efficiency) of 95 percent for solvent storage tanks, mix preparation
equipment, coating operations, waste handling devices, and condenser
vents in solvent recovery. If an incinerator is used to control these
emission points, an alternate emission limit of 20 ppmv is allowed.
For wastewater treatment systems, either 99 percent of the HAP
present in the wastewater discharge must be removed, or an outlet HAP
concentration of less than 50 parts per million by weight (ppmw) must
be achieved.
For the wash sinks, emissions must be controlled by 88 percent.
This can be achieved by maintaining a 75-percent freeboard ratio.
Alternatively, an owner or operator can control HAP emissions from wash
sinks by venting them to a 95-percent efficient control device.
Equipment standards are required to control emissions from
particulate transfer operations and the cleaning of fixed lines by
flushing.
For the transfer of particulates from the holding tanks to the
mixing area, the proposed standards require that an enclosed transfer
device as defined in Sec. 63.702 must be used to transfer particulates
containing HAP.
For the flushing of fixed lines with solutions containing HAP, the
proposed standards require that the lines be flushed using a closed
system as described in Sec. 63.702. As an alternative to using a closed
system, an owner or operator may flush the line into an open container.
However, that container must be in an enclosure (such as the type
surrounding the coater) that is vented to a control device such that
the overall control is 95 percent.
The proposed standards would require the owner or operator of an
existing magnetic tape operation to comply with these standards within
1 year after they are published in the Federal Register. Section
63.7(a)(2) of the proposed General Provisions, if promulgated, would
then allow a source 120 days after the compliance date to demonstrate
compliance through an initial performance test.\1\ The Administrator
feels that this timeframe is sufficient for existing sources to comply
with the regulation. A longer compliance timeframe is not necessary
because many of the sources in the source category have already
instituted the control techniques required to meet the proposed
standards. A shorter timeframe was not selected because the proposed
timeframe is necessary for those sources that will be required to
install new capture and/or control devices to purchase and install the
equipment.
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\1\The EPA proposed regulations for subpart A of 40 CFR Part 63
were published in the Federal Register on August 11, 1993 at 58 FR
42760. Sources covered by subpart EE will need to comply with
whatever deadlines for performing the initial performance test are
contained in subpart A, and all other applicable provisions of
subpart A, as finally promulgated.
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Owners or operators of facilities initially determined to be area
sources that become major sources are subject to the rule under the
same compliance timeframe as established for existing major sources.
That is, area sources that become major sources will have to comply
within one year of becoming a major source.
Owners or operators of new sources that commence construction after
the standards are proposed but before the standards are promulgated
will have to comply immediately upon startup, unless the promulgated
regulation is more stringent than the proposed regulation. In
accordance with Section 112(i)(2) of the Act, if the promulgated
standards are more stringent than the proposed standards, the
compliance date for sources that commence construction after proposal
but before promulgation will be 3 years after the promulgation date,
provided the owner or operator complies with the standards as proposed
until the compliance date.\2\ The owner or operator would then be
required to conduct a performance test within 120 days after the
compliance date.
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\2\Section 63.7(a)(2)(ix) of the proposed General Provisions
implements this requirement.
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All other new sources will have to comply with the proposed
standards immediately upon startup.
C. Monitoring Requirements
Monitoring is required by the proposed standards to determine
whether a magnetic tape operation is in continuous compliance.
Depending on the control system, this can be accomplished by: (1)
Continuously measuring inlet and outlet concentration and showing that
the control efficiency corresponds to that required by the standard; or
(2) Continuously measuring site-specific operating parameters, the
values of which are established by the owner or operator during the
initial compliance test. The operating parameter value is defined as
the minimum or maximum value established for a control device or
process parameter that, if achieved by itself or in combination with
one or more other operating parameter values, determines that an owner
or operator is complying with the applicable emission limitation or
standards. This type of enhanced monitoring would be required for those
emission points for which the standards are expressed as a percent
control. For equipment standards, no monitoring would be required.
However, the owner or operator is expected to install and operate the
equipment properly (for particulate transfer and flushing fixed lines).
For owners or operators complying with the proposed standards for wash
sinks by maintaining a freeboard ratio, compliance would be
demonstrated through recordkeeping (see section VI.K). A summary of the
monitoring requirements of the proposed standards is provided in table
2.
Table 2.--Proposed Enhanced Monitoring Requirements
------------------------------------------------------------------------
Control device Parameter(s) to monitor Deviation
------------------------------------------------------------------------
1. Carbon adsorber:
If used only to Perform a material balance Material balance
control (3-day rolling average) indicates control
affected comparing solvent applied efficiency is less
coating at the coater to solvent than stipulated by
operation and recovered. NESHAP.
solvent is
recovered..
Multiple beds Continuous measure of outlet Monitored outlet
on adsorber total VOC concentration if concentration is
exhaust compliance is based on greater than the
through a outlet concentration; or value established
common stack.. during the
performance test for
three consecutive
adsorption cycles.
Continuous measure of inlet Efficiency is less
and outlet total VOC than that stipulated
concentration if compliance by the NESHAP for
is based on control three consecutive
efficiency. adsorption cycles.
Adsorber has Continuous measure of outlet 3-day rolling average
individual total VOC concentration if for an adsorption
exhaust stacks compliance is based on vessel indicates an
for each of outlet concentration; or outlet concentration
multiple beds.. that is greater than
the value
established during
the performance
test.
Continuous measure of inlet 3-day rolling average
and outlet total VOC for an adsorption
concentration if compliance vessel indicates
is based on control efficiency is less
efficiency. than that stipulated
by the NESHAP.
2. Condenser:
If used only to Perform a material balance Material balance
control (3-day rolling average) indicates control
affected comparing solvent applied efficiency is less
coating at the coater to solvent than stipulated by
operation and recovered. NESHAP.
solvent is
recovered..
If used to Continuous measure of the For any 3-hour
control temperature of condenser period, the average
coating exhaust stream; or exhaust temperature
operation and is greater than the
other emission average exhaust
points.. temperature
established during
the performance
test.
Continuous measure of inlet For any 3-hour
and outlet total VOC period, the average
concentration if compliance control efficiency
is based on control is less than that
efficiency. stipulated by the
NESHAP.
3. Thermal Continuous measure of the For any 3-hour
incinerator. combustion temperature; or period, the average
combusition
temperature is less
than the average
combustion
temperature
established during
the performance
test.
Continuous measure of outlet For any 3-hour
VOC concentration if period, the average
compliance is based on outlet VOC
outlet concentration; or concentration is
greater than that
required by the
standard.
Continuous measure of inlet For any 3-hour
and outlet total VOC period, the average
concentration if compliance control efficiency
is based on control is less than that
efficiency. stipulated by the
NESHAP.
4. Catalytic Continuous measure of the For any 3-hour
incinerator. gas temperature both period, the average
upstream and downstream of gas temperature
catalyst bed; or before and after the
catalyst bed, or the
average gas
temperature
difference across
the catalyst bed, is
less than the
average temperature
established during
the performance
test.
Continuous measure of outlet For any 3-hour
VOC concentration if period, the average
compliance is based on outlet VOC
outlet concentration. concentration is
greater than that
required by the
standard.
Continuous measure of inlet For any 3-hour
and outlet total VOC period, the average
concentration if compliance control efficiency
is based on control is less than that
efficiency. stipulated by the
NESHAP.
5. Capture system.. Continuous measure of an For any 3-hour
indicator parameter (e.g. period, parameter
differential pressure). readings are outside
the value
established during
the performance
test.
6. All air Flow diversion: if bypass Presence of flow
pollution control lines that could divert detected in the
devices. flow from the control line, rupture of the
device to the atmosphere car-seal, or removal
exist, flow must be of the lock-and-key
monitored continuously or must be reported in
the line must be secured the quarterly
with a car-seal or lock-and- reporting required
key type configuration that by Sec. 63,10.
is inspected monthly. Occurrence does not
establish
noncompliance.
7. Steam strippers. Continuous measure of the For any 3-hour
steam and wastewater feed period, the average
rates. steam to fee ratio
is less than the
average value
established in the
compliance
determination.
------------------------------------------------------------------------
The operating parameter value monitoring system shall complete a
minimum of one measurement cycle (sampling, analyzing, recording) for
each successive 15-minute period in accordance with
Sec. 63.8(c)(4).3
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\3\The EPA proposed regulations for subpart A of 40 CFR Part 63
on August 11, 1993 at 58 FR 42760. Sources covered by subpart EE
will need to comply with the provisions of subpart A as finally
promulgated.
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D. Test Methods for Compliance
The product of the capture efficiency of the system and the
efficiency of the control device yields the overall efficiency of the
control system. Sources can demonstrate that the overall HAP control
efficiency required by the proposed rule is being met by: (1) Measuring
the capture and control efficiency; or
(2) Performing a liquid-liquid material balance, if a solvent
recovery device is used to control the coating operation only.
The proposed rule allows several ways to calculate the capture
efficiency. The first way to calculate the capture efficiency is to
perform a capture efficiency test in accordance with the provisions of
Sec. 63.705(c) (2) or (3). Another way to demonstrate 100-percent
capture is to meet the total enclosure criteria of Sec. 63.705(c)(4).
The capture efficiency associated with using piping or ductwork to
direct emissions from an affected emission source to a control device
is 100 percent if the requirements of Sec. 63.705(d)(1)(i) are met.
To calculate the efficiency of the control device or to measure the
outlet concentration, the proposed standards allow the use of either
the EPA Method 25A or the EPA Method 18, both of which are found in 40
CFR part 60, appendix A. The EPA Method 25A, which measures control
device efficiency for organic compounds, is the minimum test method
proposed to demonstrate initial compliance with the proposed standards.
The EPA Method 18, which can distinguish control efficiencies for
different species of HAP, is also allowed as an alternative testing
method.
In certain instances, a liquid-liquid material balance conducted in
accordance with Sec. 63.705(c)(1) is proposed to demonstrate ongoing
compliance with the proposed standards. For a solvent recovery device
that controls only the coating operation, a liquid material balance is
performed by continuously measuring solvent applied at the coater. The
overall HAP control efficiency is then calculated over a 3-day rolling
averaging period. A rolling average is the overall average of the
individual averages calculated during a given time period.
The proposed rule requires that the HAP in the wastewater discharge
from a wastewater treatment system be treated by: (1) Using a steam
stripper designed to be 99-percent efficient;
(2) Using a steam stripper such that the total HAP concentration of
the water discharged from the steam stripper is less than 50 ppmw; or
(3) Using an alternate treatment device, approved by the
Administrator, which removes 99 percent of the HAP or reduces HAP to a
concentration of less than 50 ppmw. Any alternate treatment device
should not allow HAP emissions to be merely transferred from the water
phase to the air phase in any uncontrolled manner. To demonstrate
compliance with the proposed rule, an owner or operator must provide
either engineering design calculations that show that the stripper is
designed to achieve a 99-percent removal efficiency, or sample the
wastewater discharged from the stripper using the EPA Method 305 to
show that a total HAP outlet concentration of 50 ppmw is being
achieved. The EPA Method 305 was proposed to be added to appendix A of
part 63 on December 31, 1992 (57 FR 62785). The engineering design
calculations would have to include, at a minimum, the feed rate, steam
rate, number of theoretical trays, number of actual trays, feed
composition, bottoms composition, overheads composition, and inlet feed
temperature. Owners or operators complying with the standards through
use of an alternate treatment device must identify an appropriate
compliance test and ongoing compliance monitoring plan, subject to the
approval of the Administrator.
If an owner or operator complies with the proposed standards for
wash sinks by venting the emissions to a control device, an overall HAP
control efficiency of 88 percent must be determined from the product of
the control device efficiency and the capture efficiency. Determination
of the overall HAP control efficiency is not required in situations
where: (1) The sources are existing sources that have been venting HAP
emissions from the wash sink to the control device since before March
11, 1994;
(2) The system venting HAP emissions from the wash sink to the
control device is in place before March 11, 1994; and
(3) The owner or operator continues venting the wash sink emissions
to the device.
If the owner or operator is an existing source but discontinues the
venting of the sink to the control device, a 75-percent freeboard ratio
must then be maintained.
E. Reporting and Recordkeeping Requirements
The owner or operator of any magnetic tape operation subject to
these proposed standards would be required to fulfill the reporting and
recordkeeping requirements outlined in Sec. 63.10, except as exempted
by Sec. 63.701(a)(2) of the proposed rule.4 These proposed
requirements include those associated with startup, shutdown, or
malfunctions; operation and maintenance records; compliance monitoring
system records; performance test reporting; quarterly reports of excess
emissions; and continuous monitoring system performance reports. The
quarterly reports must contain the monitored value for the periods
constituting exceedances, and a description and timing of steps taken
to address the cause of the exceedances. Owners or operators of
facilities described in Sec. 63.701(a)(2) are not subject to these
requirements of part 63, subpart A. However, such affected sources are
subject to the requirements of Sec. 63.703(g), and must record the
amount of HAP utilized annually and report that quantity to the
Administrator.
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\4\Ibid.
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In addition to the above-proposed requirements, it is proposed that
whenever solvent is added to the wash sink, the owner or operator of a
magnetic tape manufacturing operation that uses wash sinks containing
HAP to clean removable parts shall calculate and record the freeboard
ratio of each sink, if maintenance of a freeboard ratio is the chosen
compliance method. Times during which a freeboard ratio of 75 percent
or greater is not maintained is a violation of the standards and should
be noted in the aforementioned quarterly reporting.
II. List of Source Categories
Section 112 of the amended Act requires that the EPA evaluate and
control emissions of HAP. The control of HAP is achieved through
promulgation of emission standards under sections 112(d) and 112(f) and
work practice and equipment standards under section 112(h) for
categories of sources that emit HAP. On July 16, 1992, the EPA
published an initial list of major and area source categories to be
regulated (57 FR 31576). Included on that list were major sources
emitting HAP from magnetic tape manufacturing operations. Thus, the
source categories to be regulated by the proposed standards are
existing and new major sources emitting HAP from magnetic tape
manufacturing operations.
There are a total of 25 facilities that make up the magnetic tape
source category. For the purposes of estimating environmental, energy,
cost, and economic impacts, an evaluation was conducted to determine
which sources would be subject to the proposed rule. Of the 25
facilities, 14 were determined to meet the major source definition. One
of these major sources is expected to fall below the solvent usage
cutoff identified in Sec. 63.701(a)(2) and will therefore only be
subject to recordkeeping and reporting requirements. The remaining 11
sources are not expected to be major and, thus, are not expected to be
regulated by these standards.
Since 1988, 17 magnetic tape manufacturing facilities have ceased
operation. However, six new coating lines were constructed; two are
located at two new plants and the remaining four were added to four
existing facilities. No new plants are expected to be built over the
next 5 years, although the trend of adding new lines to existing
facilities is expected to continue at the same rate. Therefore, six new
lines are expected to be built over the next 5 years, an approximate
rate of one per year.
III. Background
Magnetic tape manufacturing operations have previously been
regulated by the EPA. The new source performance standards (NSPS) for
the magnetic tape manufacturing industry were promulgated on October 3,
1988 (53 FR 38892). The NSPS are national standards that limit volatile
organic compound (VOC) emissions from the coating operation and the mix
preparation steps at new magnetic tape manufacturing facilities.
The NSPS include control requirements for new coating operations
using greater than or equal to 38 cubic meters (m\3\) (10,000 gallons
[gal]) of solvent per year and for modified or reconstructed coating
operations using 370 m\3\ (98,000 gal) of solvent per year. Coating
operations that are below these solvent usages are subject only to
reporting and recordkeeping requirements.
The NSPS require new coating operations to recover or destroy 93
percent of the VOC content of the solvent applied at the coater. This
same requirement applies to any modified or reconstructed coating
operation that was achieving less than 90-percent control when it was
modified or reconstructed. However, an existing coating operation that
demonstrates an overall VOC control efficiency greater than or equal to
90 percent before modification or reconstruction is not required to add
additional controls but has to maintain an overall control level equal
to or greater than the previously demonstrated control (up to an
overall VOC control efficiency of 93 percent).
The NSPS also require new mix preparation equipment to be covered
and vented to the 95-percent efficient control device if it is
constructed concurrently with any control device other than a
condenser. For other cases, at a minimum, mix preparation equipment has
to be equipped with a cover meeting particular specifications.
Under the NSPS, sources can also comply with the rule by using
coatings that contain a maximum of 0.2 kilograms of VOC per liter of
coating solids as calculated on a weighted average basis for each
nominal 1-month period. Since the promulgation of the NSPS, no source
subject to the rule has complied by meeting this provision of the
standards.
As of the date of proposal of the NSPS (January 22, 1986), any new,
modified, or reconstructed lines in any State are subject to the NSPS.
As of March 1993, six coating lines are known to be subject to the
NSPS.
In addition to the NSPS, several State regulations that apply to
the magnetic tape manufacturing industry have been developed. Twenty-
eight States limit VOC emissions by requiring that the coatings used
contain less than 347 grams per liter (g/L) (2.9 pounds per gallon [lb/
gal]) of coating applied, excluding water. This applies to 12 operating
facilities and was recommended by a 1977 Federal control techniques
guideline (CTG) for existing stationary sources (``Control of Volatile
Organic Emissions from Existing Stationary Sources--Volume II: Surface
Coatings of Cans, Coils, Paper, Fabrics, Automobiles, and Light-Duty
Trucks,'' Document No. EPA-450/2-77-008). Based on the average VOC
content of the coatings used by the magnetic tape industry, this is
approximately equal to 83-percent control. Two States limit VOC
emissions by requiring that the coatings used contain less than 359 g/L
(3.0 lb/gal) of VOC. One facility is located in one of those States and
is therefore subject to this requirement. Five facilities in California
are subject to rules that limit the VOC content of their coatings to
either 120 g/L (1.0 lb/gal) or 264 g/L (2.2 lb/gal) of VOC, depending
upon local district regulations. All of the above coating limits can
also be met through the use of add-on controls, which is the method all
known magnetic tape facilities have chosen for compliance. Finally,
four facilities are located in ozone attainment areas regulated by the
national ambient air quality standards and are not subject to
additional control requirements at this time.
There has also been some regulation of VOC emissions from cleaning
activities in the magnetic tape industry. In California, the Bay Area
Air Quality Management District requires that owners or operators
maintain a minimum freeboard ratio in their wash sinks or vent wash
sink emissions to a control device. Four facilities are located in the
California Bay Area. Illinois requires facilities with VOC emissions
greater than 110 Mg/yr (100 tons/yr) that are located in nonattainment
areas to cover vessels during cleaning. However, there are no known
magnetic tape manufacturing sources with VOC emissions above this level
located in Illinois.
In developing today's proposed standards under the Act, the Agency
used the information gathered through its previous regulatory
activities, described above, to the greatest extent possible. The
status of the proposed standards and the basis for selecting the
regulatory alternatives were presented to the National Air Pollution
Control Techniques Advisory Committee (NAPCTAC) in November 1992 at a
meeting attended by industry, State and local regulatory agency
representatives, and representatives from environmental groups.
IV. Authority for National Emission Standards for Hazardous Air
Pollutants Decision Process
A. Source of Authority for NESHAP Development
Section 112 of the Clean Air Act gives the Environmental Protection
Agency the authority to establish national standards to reduce air
emissions from sources that emit one or more HAP. Section 112(b)
contains a list of HAP to be regulated by NESHAP. Section 112(c)
directs the Agency to use this pollutant list to develop and publish a
list of source categories for which NESHAP will be developed; this list
was published in the Federal Register on July 16, 1992 (57 FR 31576).
The Agency must list all known categories and subcategories of ``major
sources'' that emit one or more of the listed HAP. A major source is
defined in section 112(a) as any stationary source or group of
stationary sources located within a contiguous area and under common
control that emits or has the potential to emit in the aggregate,
considering controls, 10 tons per year or more of any one HAP or 25
tons per year or more of any combination of HAP.
B. Criteria for Development of NESHAP
The NESHAP are to be developed to control HAP emissions from both
new and existing sources according to the statutory directives set out
in section 112(d) of the Act. The statute requires the standards to
reflect the maximum degree of reduction in emissions of HAP that is
achievable for new or existing sources. This control level is referred
to as the ``maximum achievable control technology'' (MACT). The
selection of MACT must reflect consideration of the cost of achieving
the emission reduction, any non-air quality health and environmental
impacts, and energy requirements for control levels more stringent than
the floor (described below).
The MACT floor is the least stringent level for MACT standards. For
new sources, the standards for a source category or subcategory ``shall
not be less stringent than the emission control that is achieved in
practice by the best controlled similar source, as determined by the
Administrator'' (section 112(d)(3)). Existing source standards should
be no less stringent than the average emission limitation achieved by
the best performing 12 percent of the existing sources for categories
and subcategories with 30 or more sources or the average emission
limitation achieved by the best performing 5 sources for categories or
subcategories with fewer than 30 sources (section 112(d)(3)).
V. Summary of Environmental, Energy, Economic and Cost Impacts
A. Environmental Impacts
This section will discuss the incremental increase or decrease in
air pollution, water pollution and solid waste generation that would
result from implementing the proposed standards. Nationwide impacts are
provided for existing sources and new sources. The impacts on new
sources are based on a projected six new lines in the industry that
would be located at existing plants; no new plants are expected to be
built. The sizes of the new lines are expected to reflect the sizes of
existing lines; four are estimated to be large, one to be medium, and
one to be small. Impacts on new sources are presented on a per-line
basis in chapter 7 of the BID (see ADDRESSES). The estimated impacts on
existing and new sources are also summarized in sections VI.C and VI.D
in comparing the two regulatory alternatives considered for the
proposed standards.
1. Air Pollution Impacts
The HAP emissions from most of the emission points can be
controlled by the use of add-on control equipment such as carbon
adsorbers, condensers and incinerators. At other emission points,
equipment standards and work practice standards are proposed to limit
HAP emissions. Emissions of VOC that are both HAP and non-HAP may be
controlled in the process of meeting the requirements for HAP removal.
The quantity of those non-HAP VOC's that will be removed, however, has
not been quantified. The estimated primary and secondary air pollution
impacts that would result from implementing each alternative are
summarized below for new and existing sources.
a. Primary air pollution impacts. The immediate air pollution
impacts caused by the proposed standards would be a reduction in the
emission of solvent HAP by the source category. At baseline conditions
(i.e., the conditions that exist in the absence of NESHAP), total
solvent HAP emissions from existing sources are estimated to be 4,060
Mg/yr (4,470 tons/yr). If the proposed standards were enacted, these
emissions would drop to approximately 1,980 Mg/yr (2,170 tons/yr). This
is a total estimated HAP emission reduction of 2,080 Mg/yr (2,300 tons/
yr). The HAP emission reduction could also potentially result in a
decline in ambient VOC levels, and therefore a reduction in ozone and
photochemical smog formation. For new sources built over the next 5
years, the proposed standards are estimated to reduce solvent HAP
emissions from a baseline level of 368 Mg/yr (405 tons/yr) to a level
of 227 Mg/yr (250 tons/yr), an incremental reduction of 141 Mg/yr (155
tons/yr).
The proposed standards are also estimated to reduce HAP
particulates from existing sources by 0.27 Mg/yr (0.3 ton/yr), from an
estimated baseline level of 0.39 Mg/yr (0.43 ton/yr) to a level of
approximately 0.12 Mg/yr (0.13 ton/yr). At new sources, particulate
emissions are expected to be reduced by approximately 2 Mg/yr (2.2 ton/
yr), from a baseline level of 2.1 Mg/yr (2.3 ton/yr) to a level of 0.12
Mg/yr (0.14 ton/yr). The baseline emissions of particulate HAP are
greater for new sources than for existing sources because of
assumptions made for new sources. All new sources were assumed to use
particulate HAP, whereas particulate HAP are not used at all existing
sources. Also, some existing sources control emissions of particulate
HAP. Since the NSPS do not require control of particulate HAP, it was
assumed that new source emissions of particulate HAP would be
uncontrolled.
b. Secondary air pollution impacts. Secondary emissions of air
pollutants result from generation of the energy needed to operate the
control devices required by the proposed standards. For those
facilities that currently operate a control device, the energy
requirements of the proposed standards are incremental, i.e., in
addition to the current energy expended at a facility. The combustion
of natural gas in incinerators will result in particulate matter (PM),
nitrogen oxides (NOx), and carbon monoxide (CO) emissions. The
combustion of fuel oil in the boiler used to produce steam for the
fixed-bed carbon adsorption system will result in PM, NOx, and sulfur
oxide (SOx) emissions.
As a result of implementing the proposed standards at existing
sources, PM emissions are estimated to increase by 1.3 Mg/yr (1.4 tons/
yr), NOx emissions are estimated to increase by 4 Mg/yr (4.4 tons/yr),
SOx emissions are estimated to increase by 17 Mg/yr (19 tons/yr), and
CO emissions are estimated to increase by less than 0.01 Mg/yr (0.01
ton/yr). The magnitude of the secondary pollutants generated by the
operation of the control devices is expected to be much smaller than
the magnitude of the HAP emissions being reduced. Under the proposed
standards, 23 Mg/yr (25 tons/yr) of secondary pollutants are
anticipated but 2,080 Mg/yr (2,300 tons/yr) of HAP emissions would be
expected to be reduced. At new sources, 0.4 Mg/yr (0.5 ton/yr) of PM
emissions, 5.4 Mg/yr (6 ton/yr) of SOx emissions, and 1.3 Mg/yr (1.4
ton/yr) of NOx emissions are estimated to be generated. Secondary
pollutants projected for new sources are based on all new sources using
carbon adsorption as a control technology. As with existing sources,
secondary impacts are expected to be small compared to primary air
pollution impacts.
2. Water Pollution Impacts
The only wastewater stream generated from magnetic tape
manufacturing operations results when the carbon bed in the carbon
adsorption system becomes saturated with HAP and is desorbed with
steam. Once the steam (containing solvent) is condensed and the solvent
removed from it, the resulting water is discharged to a POTW. (See
discussion of wastewater treatment systems in section VI.B.) Because
the proposed standards require that additional HAP air emissions be
controlled over baseline conditions, more HAP may be processed through
the wastewater treatment system. Because steam will be used, a greater
quantity of water is expected to be discharged. It has been estimated
that at existing sources an additional 5,600,000 L (1,460,000 gal)
would be discharged under the proposed standards. This wastewater is
from the three major sources that are known to perform wastewater
treatment (as defined in the proposed rule) onsite. Assuming a HAP
content of 50 ppmw in the wastewater, the waterborne HAP discharged
from this source would be 0.28 Mg/yr (0.31 ton/yr). At new sources, the
wastewater discharge that would result is estimated to be 1,024,000 L/
yr (271,000 gal/yr). The associated HAP discharged in this wastewater
is estimated to be 0.05 Mg/yr (0.06 ton/yr).
3. Solid Waste Impacts
The only solid waste impacts from the add-on control systems come
from carbon adsorption units. Solid waste impacts resulting from the
proposed standards are only those impacts that are in addition to the
solid waste currently generated at a magnetic tape manufacturing
operation (i.e., incremental over baseline). It is assumed that the
control of the additional emission points at an affected source that
has an existing carbon adsorption system would not decrease the life of
the carbon bed. Thus, there are no incremental solid waste impacts from
these sources. Solid waste will result from existing sources that
require new carbon adsorption systems in order to comply with the
proposed standards. It is estimated that one existing source will add a
carbon adsorption system to meet the requirements of the proposed
standards. The annual solid waste impacts of the proposed standards
that are expected to result from the operation of the new carbon
adsorption system are estimated to be less than 0.1 Mg/yr (0.1 ton/yr).
Likewise, for new sources, solid waste impacts will only result from
the addition of small lines that are installed at a currently
uncontrolled plant. These impacts are estimated to be less than 0.01
Mg/yr (0.01 ton/yr). All of these impacts were determined under the
assumption that carbon beds have an average life of 5 years.
B. Energy Impacts
The energy impacts from the proposed standards are a result of: (1)
The additional natural gas required by those facilities currently using
incineration,
(2) The fuel necessary to produce the additional steam required by
existing carbon adsorption systems, and
(3) The additional electricity requirements associated with control
device operation as well as the operation of the ventilation fan
required for controlling particulate HAP emissions.
Under the proposed standards for existing sources, natural gas
consumption is estimated to increase by 70 GJ/yr (65 x 106 Btu/
yr), steam consumption is estimated to increase by 20,160 GJ/yr (19,125
x 106 Btu/yr), and electricity consumption is estimated to
increase by 600 GJ/yr (570 x 106 Btu/yr). The total increase in
energy requirements for existing sources would be 20,830 GJ/yr (19,760
x 106 Btu/yr). For new sources it is assumed that carbon
adsorption systems would be used because this is the type of control
device used predominantly in the industry. The increase in steam
consumption would be approximately 6,430 GJ/yr (6,100 x 106 Btu/
yr) and the increase in electricity consumption would be approximately
33 GJ/yr (31 x 106 Btu/yr).
C. Economic Impacts
The economic impact analysis estimates that only one affected
source may experience adverse economic impacts. This result should not
adversely affect the magnetic tape manufacturing industry, the economy,
competition, or any other economic concerns.
An analysis was conducted to assess the economic impacts of the
proposed regulation. Price, output, and employment impacts were
calculated on a facility-specific basis as well as on an industry-wide
basis. A worst-case scenario was used to calculate the facility-
specific impacts.
The analysis calculated price impacts on magnetic tape products
such as blank recording, audio, and computer media. The facility-
specific impact calculations indicated that in order for each facility
to recover its control costs fully, a minimum price increase of
approximately 0 percent would be required of some facilities while a
maximum price increase of approximately 5 percent would be required of
the marginal facility. Of the 13 facilities for which impacts were
calculated, 4 facilities were predicted to be required to increase
their prices by approximately 1 percent or greater.
The analysis recognized, however, that some facilities may be able
to absorb a portion of their increased costs. Therefore, an additional
analysis was conducted for the 4 facilities expected to experience
price increases of approximately 1 percent or greater. An examination
of the regulation's effect on the facilities' net income and capital
availability revealed that one facility would be significantly
impacted. This facility has been identified as a small business.
The economic analysis also examined the proposed regulation's
impact on industry output and employment. The magnetic tape industry is
expected to experience a 0.1-percent reduction in output. Assuming a
one-to-one relationship between output and employment, the industry can
also be expected to experience a similar reduction in employment.
D. Cost Impacts
For existing major sources, the proposed standards are estimated to
result in a total industry-wide capital investment of $2,263,600. This
cost includes the capital cost of control devices required to achieve
compliance with the proposed standards. The annual cost associated with
the proposed standards is $400,120/yr. This cost includes the capital
cost of control (annualized, assuming a 7-percent interest rate and a
10-year equipment life), annual compliance costs including initial
performance tests and ongoing monitoring, and annual reporting and
recordkeeping costs. The annual control cost is approximately $174,240/
yr, the annual compliance cost is approximately $115,640/yr, and the
annual reporting and recordkeeping costs are approximately $110,240/yr.
The associated cost effectiveness of the proposed standards is
estimated as $190/Mg ($170/ton). For new sources, the costs vary
depending on whether a carbon adsorber or an incinerator is the control
device used. With either system, the total capital investment of the
proposed standards is approximately $500,000. The total annual costs,
which include all of the items cited above, are estimated to be
$349,360/yr, with an associated cost effectiveness of $2,470/Mg
($2,250/ton) if a carbon adsorption system is used. To compare the
costs of various control devices, the cost analysis was also repeated
assuming incineration was used at new sources. If an incinerator is
used, the annual costs are estimated as $270,367 with an associated
cost effectiveness of $1,910/Mg/yr ($1,740/ton/yr).
VI. Rationale
This section describes the decisions made by the Administrator to
select the proposed standards.
A. Selection of Pollutant and Source Category for Control
In this section, the pollutants and source category selected for
control by the proposed standards are identified. The potential for
subcategorization and the solvent usage cutoff established for this
source category are also discussed. Finally, a discussion of area
source regulation is presented.
1. Identification of Pollutants and Source Category
Magnetic tape manufacturing operations are sources of both VOC and
particulate emissions. The specific pollutants regulated by the
proposed standards are those VOC's and particulates that are listed as
HAP in section 112(b) of the amended Act.
The solvent HAP typically used in the magnetic tape manufacturing
industry are methyl ethyl ketone (MEK), methyl isobutyl ketone (MIBK),
toluene, xylene, and ethyl benzene. These HAP are used predominantly in
the coating operations. The HAP used for cleaning are most typically
MEK and toluene. All of these HAP are also VOC's. Other non-HAP
solvents that are used in magnetic tape operations are tetrahydrofuran,
cyclohexanone, and acetone. Acetone is used only for those magnetic
tape manufacturing operations involving a paper substrate.
Particulates, which are magnetic particles containing iron, chrome,
and/or cobalt, are also used in this industry. The particulate HAP used
are those containing cobalt and chromium.
As discussed earlier, the list of source categories for which
NESHAP will be developed was published in the Federal Register on July
16, 1992 (57 FR 31576), and includes major sources performing magnetic
tape manufacturing operations. Thus, emissions of HAP from new and
existing major magnetic tape manufacturing operations are being
regulated by the proposed rulemaking.
Products that are manufactured as a result of magnetic tape
manufacturing operations include magnetic products such as audio and
video tape and computer diskettes, and non-magnetic products such as
leader tape. Leader tape is the tape at the beginning of an audio or
video cassette that does not contain magnetic media; it is manufactured
using the same methods as magnetic tape. Therefore, leader tape
production is included in the definition of magnetic tape manufacturing
operations.
There may also be some facilities in this source category that
produce multiple products, some that involve magnetic media and some
that do not. In cases where the nonmagnetic tape products are produced
using the same pieces of equipment as the magnetic tape products, and
the manufacture of nonmagnetic products uses HAP such as HAP solvent,
the Agency is proposing that the pieces of equipment being used for
both magnetic and non-magnetic products be controlled, regardless of
which product is being manufactured. The process (and hence emissions
of HAP) is essentially the same except that no magnetic particles are
added to the coating mix. The control systems would be in place and
would be applicable for both products. This regulation, therefore,
applies to all products produced at magnetic tape production facilities
(provided HAP are used in the production), regardless of whether
magnetic particles are added to the coating mix, as long as the same or
some of the same equipment is used. Equipment that coexists with
magnetic tape equipment but is never used in magnetic tape
manufacturing does not need to be controlled even if HAP are emitted.
At sources where research or laboratory facilities are collocated
with production lines, the research or laboratory facilities are
subject to the proposed standards. The close proximity of these lines
allows control of the research or laboratory facilities by production
line control devices. The mix of solvents used in research or
laboratory facilities may differ from those used on production lines,
and affect operation of the control device. Therefore, the costs to
control the variety of solvents that would be used in research or
laboratory facilities were considered in calculating control costs.
The proposed definition of research or laboratory facility is from
section 112(c)(7) of the CAA. One of the criteria in the definition is
that the facility is not engaged in the manufacture of products for
commercial sale, except in a de minimis manner. The EPA is soliciting
comments on what the sale of products in a de minimis manner would be
for the magnetic tape manufacturing industry, including if research
facilities sell any products.
The process for manufacturing magnetic and leader tape consists of
mixing the coating ingredients (magnetic particles for magnetic tape,
resins and solvents for both types of tape), conditioning the base
film, applying the coating to the base film
(either a plastic or paper substrate), orienting the magnetic particles
(magnetic tape), removing the solvents by evaporation in a drying oven,
and finishing the tape by calendering, rewinding, slitting, testing,
and packaging. Most of the HAP emissions from magnetic tape
manufacturing operations result from the coating operation, and to a
lesser degree from the ancillary activities such as solvent storage,
mix preparation, transferring solvent through piping, equipment
cleaning, treatment of solvent-laden waste material, and wastewater
treatment.
This source category was evaluated to determine if
subcategorization was appropriate. The Agency's analysis indicates that
no subcategorization is necessary. There are no distinct process
differences within the source category and no distinction between sizes
of facilities in terms of what controls are technically feasible. Both
small and large existing sources have implemented the control
technologies that form the basis for MACT.
2. Criteria for Applicability Determination
Only major sources are being regulated by the proposed standards. A
source is considered major if it has the potential to emit, considering
controls, greater than 9.1 Mg/yr (10 tons/yr) of any one HAP or 22.7
Mg/yr (25 tons/yr) of multiple HAP. (Area sources were evaluated to
determine if they should be regulated; see discussion that follows.)
One way to make the determination of whether a source is an area source
or a major source is to conduct a facility-wide material balance of
solvent and particulate HAP used at the plant. Any HAP that is not
recovered or controlled contributes to the potential HAP emissions from
a facility. It is important to note that the major source determination
is based on the total, potential HAP emitted annually inside the
fenceline of a facility, not just from magnetic tape manufacturing
operations. Potential emissions are estimated assuming operations occur
24 hours per day, 365 days per year.
For this source category, a solvent usage cutoff has also been
proposed. Major sources that use less than 9.1 Mg/yr (10 tons/yr) of
any one HAP or 22.7 Mg/yr (25 tons/yr) of multiple HAP are only subject
to an annual reporting requirement (Sec. 63.703(g) of the proposed
regulation), and are not subject to the control provisions of these
standards or to some provisions of part 63, subpart A. A solvent usage
cutoff was proposed to mitigate the impacts on some facilities in the
industry as a result of the definition of potential to emit. The
``potential to emit'' is defined in part 70 and the proposed General
Provisions to part 63 (58 FR 42760) as, ``the maximum capacity of a
stationary source to emit a pollutant under its physical and
operational design,'' and ``any physical or operational limitation on
the capacity of the stationary source to emit a pollutant, including
air pollution control equipment and restrictions on hours of operation
or on the type or amount of material combusted, stored, or processed,
shall be treated as part of its design if the limitation or the effect
it would have on emissions is federally enforceable.''
For the magnetic tape industry, it is conceivable that a plant
would be physically and operationally designed to operate 24 hours per
day, 365 days per year, because coating operations are continuous. This
is particularly true for those facilities whose primary products are
magnetic media and whose operations have been reported to operate on a
more or less continuous basis. Some facilities, however, may produce
magnetic tape as only one segment of their total manufacturing process.
For example, one plant is known to produce magnetic tape on a limited
basis and operate the magnetic tape coating lines for only a few days
every year, so its actual emissions are much less than 10 tons/yr of
any one HAP or 25 tons/yr of multiple HAP. It is unlikely that this
plant would begin producing magnetic tape on a continuous basis. Based
on potential to emit, however, this facility could be considered a
major source and therefore be subject to all requirements of the
proposed standard.
The cutoff value was selected so that it would not allow any major
source that actually emits more than 10 tons/yr of any one HAP or 25
tons/yr of multiple HAP to be exempt from the control requirements. The
solvent usage cutoff is equal to the major source emissions criteria
because in the absence of control, almost all of the solvent used by a
facility would be emitted. Therefore, even if a facility had no
controls in place, if the solvent usage were below the cutoff, it would
not be emitting greater than 9.1 Mg/yr of one HAP or 22.5 Mg/yr (25
tons/yr) of multiple HAP.
As discussed above, a cutoff established at this level would ensure
that all major sources are subject to the proposed control
requirements. However, once an owner or operator is subject to all
control provisions of the standards by virtue of being a major source
and exceeding the solvent usage cutoff, the usage cutoff is no longer a
basis for determining applicability to the control requirements. That
is, a subsequent reduction in HAP solvent usage alone would not be
sufficient to allow a source to avoid compliance with the proposed
controls. The reason for this is that the source would already have the
controls in place and operational. Therefore, the source should
continue to operate them according to the rule.
Based on information currently available to the EPA, only one
existing facility is a major source that would be exempt from the
proposed control requirements because its solvent usage is estimated to
remain below the proposed solvent usage cutoff. This source would still
be subject to the annual solvent usage reporting and recordkeeping
requirement required by 63.703(g).
3. Area Source Evaluation
The Act provides the Administrator with authority to regulate area
sources. An area source is defined as one that is not a major source.
In order to list a category of area sources for regulation, the
Administrator must find that the sources in a category, individually or
in aggregate, pose a threat of adverse effects to human health or the
environment, warranting regulation under section 112.
For the purpose of estimating the number of major sources, the
Agency examined each source's potential to emit, considering controls.
Many of the magnetic tape manufacturing operations already have
emissions controls in place that reduce their emissions to below the
criteria for major sources. For estimating the number of major sources,
the Agency assumed that the emission limitations would be federally
enforceable, and therefore highly controlled sources would not be
``major'' for the purposes of the magnetic tape manufacturing NESHAP.
Of the 25 known facilities in this source category, 11 are considered
to be area sources based on the Agency's estimate of their potential
HAP emissions. The data available on the area sources were evaluated to
determine whether regulation of area sources should be proposed.
Two of the area sources are research or laboratory facilities as
defined by section 112(c)(7) and as such are not subject to the
standards. (Research or laboratory facilities collocated with
production facilities are subject to the standards.) Area source 3 uses
particulate HAP only; emissions are estimated to be less than 1 pound
per year. Area source 4 uses a combination of HAP and non-HAP solvent;
because the quantity of HAP solvents used is less than the quantity of
non-HAP solvents, total HAP emissions are low, approximately 5 Mg/yr.
Area source 5 also uses a combination of HAP and non-HAP solvents in
their magnetic tape operations. At one time Area source 5 was
considered a major source, but this source has recently implemented
strict controls on cleaning solvent emissions. Based on the Agency's
estimate of the reduction in solvent emissions, this source is now
considered an area source. Area source 6 also uses HAP and non-HAP
solvents, and most of the solvents used are HAP. However, this
particular source is highly controlled and is therefore only emitting
approximately 5 Mg/yr of HAP. Area sources 7 through 11 do not use any
HAP in magnetic tape operations. Therefore, unless they switch their
operations to begin using HAP, they are not subject to the standards.
None of these sources are collocated at major sources. If any of these
area sources becomes a major source, they would have to notify the
Agency and will have 1 year from the date on which they became major
sources to install control devices to conform to the proposed standard.
As noted above, section 112(c) states that categories of area
sources emitting HAP may be listed and regulated if the Administrator
finds the sources, individually or in the aggregate, present a threat
of adverse effects to human health or the environment (see 57 FR 31576:
July 16, 1992, for further discussion of this statutory language). To
determine a threat of adverse effects, the Agency examines available
data on facilities, emissions, and health and environmental effects of
the emitted HAP. In this case, the Agency has adequate health data for
determining whether there is a likely threat of adverse effects to
humans for area sources emitting toluene and MEK. The Agency conducted
a screening analysis of sources emitting these chemicals, either alone
or in combination. Based on this analysis, the Agency does not believe
there is a threat of adverse effects from the area sources of magnetic
tape facilities that emit these two chemicals. For the remaining
emitted HAP, data required to determine the potential for adverse
effects are inadequate. As such, the Agency is unable to determine
whether there is a threat of adverse effects from area sources emitting
any other combination of HAP. The Agency may repeat the analyses of
these sources in the future, to evaluate the potential for human health
and environmental effects, if appropriate data become available. Until
such analyses are conducted, the Agency will not regulate area sources
in this rule.
B. Selection of Emission Points
The Agency examined all known HAP emission points associated with
the manufacturing of magnetic tape for potential control. They are
described below.
a. Solvent storage tanks. Small tanks are generally used to store
the solvent HAP, which may be virgin material, spent solvent from
cleaning or from off-specification mixes, or solvent from any stage of
the solvent recovery process. The tanks operate at or slightly above
atmospheric pressure. A facility typically has from 1 to 12 storage
tanks, with a total capacity ranging from 757 to 75,700 liters (L) (200
to 20,000 gallons [gal]). Storage tanks, as discussed in the proposed
rulemaking, do not refer to tanks that are part of the process (e.g.,
mix preparation equipment). The HAP emissions from storage tanks to the
air occur through working losses during tank loading or breathing
losses due to diurnal temperature changes.
b. Mix preparation equipment and particulate transfer operations.
The mix preparation usually takes place in a room or rooms separate
from the coating line. The components of the mix are first blended and
then transferred to a series of mills to disperse the aggregates of
magnetic particles without reducing particle size. The mix is
circulated and filtered in holding tanks to prevent binders from
curing, metal particles from settling out, and to remove any oversize
contaminants. The coating mix is pumped to and from the different
pieces of mix preparation equipment through closed lines. The mix
preparation equipment to be controlled by the proposed standards
includes all of the equipment used in preparing the coating mix
including mixers, holding tanks, and polishing tanks. Mills, which are
pressurized equipment used for thoroughly dispersing the aggregates of
magnetic particles without reducing particle size, are not included as
mix preparation equipment. This is because these pieces of equipment
are under pressure and, as such, no emissions are expected, nor could
they be vented to a control device.
Particulate HAP can either be transferred through closed systems or
can be manually poured through hatches in the covers of the mix
preparation equipment. A small amount of particulate HAP is emitted
while transferring particulate from the bag or storage bin to the mix
tank.
c. Coating operation. In the coater, the substrate to be used for
the magnetic or leader tape passes over a support roll while the
coating mix is applied. The thickness and amount of coating applied
vary with the product. During the coating application step, some
solvent HAP will volatilize. The amount that is emitted depends on
site-specific variables such as the coating mix composition and the
type of coater. Immediately following the coater, magnetic tape is
guided through an orientation field consisting of an electromagnet or
permanent magnet, which aligns the individual magnetic particles in the
direction of the intended recording. (Leader tape does not go through
the orientation process because magnetic particles are not used.) The
magnetic or leader tape is passed through a drying oven, where the
remaining solvents in the coating mix evaporate. It is expected that
any solvents on the coated tape that are going to evaporate will do so
by this point in the process. Therefore, there is no solvent
evaporation in subsequent steps. After drying, the finished product may
be: (1) Calendered to compact the dry coating and to smooth the
surface;
(2) Slit to the desired width; and
(3) Packaged and labelled, either in parts produced in-house or in
pre-purchased plastic casings.
d. Cleaning activities. Cleaning is a task performed differently at
each plant. Some plants may clean equipment between each batch of
coating, while others may clean only between product changes. Sometimes
virgin solvent is used once and immediately treated as a waste. At
other plants, cleaning solvent may be used several times before it is
considered ``spent.''
Four basic categories of cleaning activities have been identified
for this industry: (1) Flushing fixed lines; (2) Cleaning tanks; (3)
Cleaning fixed exterior surfaces; and (4) Cleaning miscellaneous
removable parts.
The flushing of fixed lines involves flushing solvent through fixed
lines not associated with the cleaning of a tank (e.g., the line from
the mix preparation equipment to the coater). A fixed line is one that
is stationary during normal operation but can be removed from its
original location for cleaning. Emissions can occur if the solvent used
for cleaning or collected after cleaning has occurred is exposed to the
air.
Tank cleaning may be either an open-top or closed-top process.
Open-top tank cleaning is the practice of cleaning a tank that either
has no cover or whose cover has been removed. Solvent may be added and
drained via buckets or pipes. The interior of the tank may be manually
cleaned with brushes while the solvent is in it. Closed-top tank
cleaning is the practice of cleaning a tank while using a cover that
seals the top of the tank. Solvent is added to and drained from the
tank via pipes. An automated brush inside the tank may scrub the sides
while the solvent is in the closed tank. Emissions occur when the
solvent used in the cleaning process is exposed to the air, and in a
closed system, equipment leak emissions also occur. Based on test data
from industry, emissions from both types of cleaning processes are
approximately equal.
Cleaning fixed exterior surfaces involves cleaning the surface area
of a fixed piece of equipment with rags or brushes. The solvent that is
on the rag or brush evaporates to the air. The surfaces to be cleaned
are typically on the coater. The ventilation system of the enclosure
around the coater draws these emissions to the outside air.
Cleaning removable parts involves cleaning parts that have been
moved from their normal position to a wash tank or sink containing
solvent. The solvent is volatile and thus evaporates into the air above
the sink. The sink is usually ventilated; thus emissions are discharged
to the atmosphere.
Rags used for miscellaneous cleaning activities will contain some
residual solvent and will therefore result in air emissions.
e. Waste handling devices. The two waste handling devices most
commonly used in the magnetic tape manufacturing industry are pot
stills and filter dryers. Both are devices in which solvents are
recovered from waste materials. In the pot still, liquid wastes are
pumped through closed piping into the pot still and heated to evaporate
the solvent portion of the waste. The filter dryer is used to treat
solid wastes such as filters, rags, and brushes, which are manually
placed in the dryer and heated to evaporate the solvent portion. With
both the pot still and the filter dryer, the evaporated solvent is
condensed, and the recovered liquid sent to a storage tank. Air
emissions may occur through the condenser vent.
f. Wastewater treatment. At a magnetic tape manufacturing facility,
the only significant source of wastewater that contains HAP results
from steam desorption of the carbon adsorption system beds used to
recover HAP air emissions. After the steam desorbs the carbon adsorber
bed, the solvent/water mixture is condensed and separated by gravity
into distinct solvent and water phases.
The solvent phase is distilled to separate it into its individual
components. Potential air emissions could result from residual solvents
in the water phase if it is not further treated prior to discharge to
the publicly owned treatment works (POTW). At magnetic tape
manufacturing facilities, the water phase is treated through steam
stripping to remove residual solvent. The solvent compounds recovered
through steam stripping are then purified into the individual solvent
components.
g. Condenser vents in the solvent recovery area. The solvent
recovery area is that area in a plant that contains the equipment used
to: (1) Remove HAP solvent from the air stream; (2) recover the
solvent; and (3) purify the solvent for reuse in the process. At a
magnetic tape manufacturing facility, this equipment would include the
control device (a carbon adsorption system or condenser), the
wastewater treatment system (in the case of carbon adsorbers), and
distillation units. Emissions of HAP to the air occur in the solvent
recovery area from atmospheric condenser vents, including condenser
vents on the steam stripper distillation columns and condenser vents to
condense steam from carbon adsorber regeneration. The vent on a
condenser that is used as a primary air emission control device is not
considered part of this emission point.
h. Equipment leaks. In magnetic tape manufacturing operations,
solvent is pumped through piping and process equipment as it travels to
or from storage tanks and from the mix preparation equipment to the
coater. Facilities that perform onsite solvent recovery and wastewater
treatment will also have process piping and equipment within these
areas. The volatile HAP will be emitted through leaks from equipment
such as pumps, compressors, pressure relief devices, sampling
connection systems, open-ended valves or lines, and flanges or any
other connecter in VOC service.
i. Packaging and labeling. This process occurs after the product
has been coated, rewound, and slit into the desired width (or punched
into diskettes). Whatever the final form of the product, printed
materials such as labels, boxes, and inserts are usually part of the
final package. Most facilities purchase these items preprinted. Two,
however, are known to print product identification codes on boxes. This
operation involves HAP solvents (contained in the ink) that volatilize
as the ink dries.
C. Selection of Basis and Level of the Proposed Standard for Existing
Sources
1. Selection of the Maximum Achievable Control Technology Floor
Section 112 requires the Agency to set standards for new and
existing sources of HAP emissions that represent the maximum degree of
reduction achievable, taking into consideration the cost of achieving
such emission reductions, as well as any non-air quality health and
environmental impacts and energy requirements. As discussed in section
IV.B., this level of control cannot be less stringent than the MACT
floor. For existing sources in source categories with less than 30
sources, such as this one, the MACT floor is the average emission
limitation achieved by the best performing 5 sources in the source
category.
The EPA is considering more than one interpretation of the
statutory language concerning the MACT floor for existing sources. In
the case of this standard, the EPA does not believe that the legal
interpretation would make a difference for most of these emissions
points. However, for particulate transfer operations (discussed later
in this section and also in section VI.G of this preamble), there is a
possibility that one of the five best performing sources in fact is
achieving a lower level of control and, in this case, the
interpretation of the MACT floor could make a difference. The EPA is
soliciting comment on the different legal interpretations of the
statutory language in a separate Federal Register notice, which is a
reopening of the comment period for the national emission standards for
hazardous organic air pollutants from the synthetic organic chemical
manufacturing industry. Persons wishing to comment on the legal
interpretations should refer to that rulemaking and submit comments to
docket number A-90-19. However, comments on the MACT floor analysis
that are specific to magnetic tape manufacturing operations should be
addressed to docket number A-91-31, as noted in the beginning of this
notice.
For this source category, information was gathered on all 25 of the
known sources in the source category through surveys, site visits, and
telephone calls. The MACT floor analysis included major sources and
sources that are not considered major for the purposes of the
nationwide impacts analysis. These area sources are the same as the
major sources in every way except that they are highly controlled and
thus are below the major source emission criteria. If these area
sources were uncontrolled, they would be considered major sources of
HAP emissions.
The MACT floor for this source category was determined on an
emission point-by-emission-point basis, which corresponds with the
proposed narrow definition of affected source (see section VI.J of this
preamble). Another way to establish the MACT floor, not used by the EPA
in this proposal, would be to identify a mass emission limit or mass
emission reduction percentage across the whole facility. The EPA does
not expect that there would be a large difference in the resulting MACT
floor for this industry if the latter approach were used. The MACT
floor for each of the emission points is identified below.
a. Solvent storage tanks. The highest level of control that was
found for storage tanks in this source category involved a closed vent
system, i.e., a system including piping, ductwork, etc., that is not
open to the atmosphere and that transports vapor to a control device.
The overall HAP control efficiency of this practice is 95 percent and
is the average level of control achieved by the five best performing
magnetic tape manufacturing operations in the source category. Thus,
the MACT floor for the storage tanks emission point is an overall HAP
control efficiency of 95 percent.
b. Mix preparation equipment. The highest level of control for
emissions from mix preparation equipment that was found in this source
category was to cover the equipment and vent the emissions to a control
device. Of the five best performing sources in this source category,
one achieves a control level of 98 percent. The others achieve a
control level of 95 percent. The average control level achieved by the
best performing five sources in this source category, therefore, is
approximately 96 percent. This control level does not correspond to any
particular control technique. Therefore, the MACT floor is based
instead on the median control level achieved by the five best
performing sources. This level is 95 percent; thus, the MACT floor is
an overall HAP control efficiency of 95 percent.
Particulate emissions may also result from coating mix preparation.
The MACT floor control level for this emission point is discussed in
subsection e, below.
c. Coating operation. The coating application and drying emission
points, collectively referred to as the coating operation, include
emissions that result from applying the coating mix at the coater and
drying the coated tape in the oven. The coating operation also includes
all equipment between the coater and the dryer.
The highest level of control that is used in this source category
to limit HAP emissions from coating operations is to vent emissions
through an enclosure to a control device. Existing sources in this
source category vent emissions through a total enclosure, thereby
capturing 100 percent of the emissions. The emissions are directed to a
control device. Of the five best performing sources in this source
category, one vents the emissions from the total enclosure to an
incinerator, achieving an overall HAP control efficiency of 98 percent.
The remaining four best performing sources vent the emissions from
their total enclosure to a control device that is 95-percent efficient,
achieving an overall HAP control efficiency of 95 percent. Thus, the
average control level achieved by the five best performing sources in
the source category is approximately 96 percent. Because this does not
correspond to any particular control technique, the median control
level of the five best performing sources (i.e., a 95-percent overall
HAP control efficiency) is the basis for the MACT floor. Thus, the MACT
floor for coating operations is an overall HAP control efficiency of 95
percent.
d. Waste handling devices. Both types of waste handling devices
(pot stills and filter dryers) used in this industry are equipped with
condensers to recover the solvent. The highest level of control for the
condenser vent that was found in this source category is venting
emissions from it to a control device. The overall HAP control
efficiency of this practice is 95 percent and is the average level of
control achieved by the five best performing waste handling devices.
Therefore, the MACT floor level of control is capture and control of 95
percent of HAP emissions.
e. Particulate transfer operations. To control particulate
emissions during mix preparation (when solid materials are transferred
into the mix preparation equipment), owners or operators in this source
category use an enclosed transfer device for transferring particulates
into the mix preparation equipment. An enclosed transfer device is a
system in which particulate HAP are conveyed from the storage bin to
the mix preparation equipment using equipment that completely contains
the transferred material, so that particulate HAP do not enter the
atmosphere as dust. The types of enclosed transfer devices currently
used in magnetic tape manufacturing facilities include vacuum injection
systems and bag slitter devices. The vacuum injection system draws
particulate from a storage container into an enclosed hopper. The
hopper uses gravity to feed a conveyer, which is also enclosed and
which carries the material to the mix preparation equipment. With a bag
slitting device, the bag of particulate raw material is placed into a
hopper, the hopper is closed, and an internal mechanism slits the bag
to release the particulate into an enclosed conveyer that feeds the mix
preparation equipment. Alternatively, the hopper may be located above
the mix preparation equipment and feed it directly.
Of the five best performing sources in this source category
controlling particulate emissions, four use enclosed transfer devices.
The average control level achieved by the five best performing sources
in the source category is the arithmetic average of the control
efficiency of the four enclosed transfer devices and the one without an
enclosed transfer device. Although the control efficiency associated
with an enclosed transfer device has not been quantified, the average
control level of the five best performing sources would not be
equivalent to any particular control technique. Therefore, the basis
for the MACT floor is the median level of control achieved by the best
performing five sources. The median level of control corresponds to the
use of an enclosed transfer device. Thus, the MACT floor is the use of
an enclosed transfer device for transferring HAP-containing
particulates.
f. Wash sinks for cleaning removable parts. Two methods of control
were found in the industry to control HAP emissions from wash sinks.
Both methods were considered to be equivalent by controlling HAP
emissions by approximately 88 percent. These methods were also the
highest level of control achieved in the source category. One control
technology involved venting the wash sink emissions through a hood
(capture device) to a control device that is 95-percent efficient. The
overall control efficiency is less than 95 percent because the capture
efficiency is less than 100 percent. The second control technique
involves maintaining a 75-percent freeboard ratio. A freeboard ratio is
defined as the vertical distance from the liquid surface to the top of
the wash sink divided by the smaller of the length or width of the sink
evaporative area. Maintaining a freeboard ratio limits solvent HAP
emissions because the solvent level in the sink is lower and solvent
vapors remain in the sink; they do not rise to the air above the sink.
When a freeboard ratio is maintained, the wash sink should not be
ventilated as this will draw the solvent vapors from the sink to the
air above it. An overall HAP control efficiency of approximately 88
percent is the average level of control achieved by the five best
performing sources in the source category, achieved either by venting
emissions from wash sinks to the control device or by maintaining a
freeboard ratio. Thus, the MACT floor is an overall HAP control
efficiency of 88 percent.
g. Cleaning involving the flushing of fixed lines. Five sources in
this source category flush the line between the coating operation and
the mix preparation equipment with solvent to remove any hardened
debris that may have collected. Three of the facilities use a closed
system, which has been determined to have negligible emissions. In a
closed system for flushing fixed lines, the empty line to be cleaned is
disconnected from its original location and connected to two other
containers. One is a closed container with cleaning solvent and the
other is a closed container that is empty. Solvent is flushed from the
container with cleaning solvent, through the line, and into the empty
container. The only solvent emissions are from vents located on the
containers. The two other major sources that perform this cleaning
operation flush the solvent through the line into an open container.
However, the container is in the total enclosure surrounding the
coater, which is vented to a control device capable of removing 95
percent of the VOC emissions. Emissions from these control systems have
not been quantified. However, emissions are thought to be very low,
regardless of which system is used. The average level of control
achieved by these five best performing sources is equal, achieved
either through a closed system or by venting emissions from an
enclosure (such as the one surrounding the coater) to the control
device. Thus, either of these control methods is the MACT floor.
h. Wastewater treatment systems. Facilities that use steam to
desorb the carbon beds of the carbon adsorption systems used for air
pollution control generate significant quantities of wastewater (5 to
10 million gallons per year). All three of the facilities using steam
to desorb the carbon adsorber beds use a steam stripper to remove HAP
compounds from the wastewater discharge. The wastewater is typically
preheated to its saturation temperature prior to being fed into the
stripping column. Upon contact with the steam, the volatile components
are transferred to the steam, and the steam/solvent mixture is removed
from the top of the column and cooled in a condenser. The resulting
water/solvent mixture is collected in a decanter; the solvent is sent
to distillation for purification, and the water is returned back to the
column. Clean water exits the bottom of the column. In this industry, a
total HAP outlet concentration of less than 50 ppmw in the outlet of
the stripper can be expected. Inlet concentrations to the column are
typically in the 2- to 5-percent range. Given these inlet and outlet
concentrations and the fact that the quantity of water entering and
exiting the column is equal, the removal efficiency is greater than 99
percent. The extent to which a compound is removed via steam stripping
is a direct function of its volatility. The HAP that are present in the
wastewater from magnetic tape facilities (MEK, MIBK, toluene) are very
volatile and thus highly strippable. In a properly-operated steam
stripper, 99 percent of these HAP compounds can be removed, with a
typical HAP concentration in the outlet from the steam stripper of less
than 50 ppmw. This is the highest level of control achievable and is in
practice at all three plants in the source category that perform this
operation (no other sources have this emission point). Therefore, the
MACT floor for this emission point is the use of a control device such
as a steam stripper that reduces the HAP content of the wastewater from
the separator by 99 percent prior to discharge to the POTW, or that
results in a total HAP concentration of less than 50 ppmw in the
wastewater discharge.
i. Condenser vents in the solvent recovery area. The condenser
vents in the solvent recovery area emit HAP to the atmosphere. One way
to control these emissions is to duct the emissions to the main control
device. The overall HAP control efficiency of this practice is 95
percent and is the average control level achieved by the five best
performing sources in the source category. Thus, the MACT floor for
this emission point is an overall HAP control efficiency of 95 percent.
j. Equipment leaks. In any magnetic tape manufacturing operation
there is equipment such as valves, flanges, pumps, and pressure relief
valves that are a source of HAP emissions. (See discussion of equipment
leak emissions in Section VI.B.) None of the major sources in this
source category control emissions from equipment leaks. Therefore, the
MACT floor is represented by a no-control level.
k. Exterior surface cleaning, tank cleaning, and packaging and
labeling. The Agency also evaluated other emission points that were
considered to contribute to HAP emissions from a facility. These other
emission points are packaging and labeling operations, tank cleaning,
and the cleaning of fixed exterior surfaces. Packaging and labeling
involves the printing of product identification codes on boxes. Tank
cleaning involves cleaning the inside of the coating mix tanks with
solvents, and sometimes involves scrubbing the tank. Spent solvent is
discharged to a waste holding container. Cleaning fixed exterior
surfaces usually involves wetting a rag with solvent and wiping the
item to be cleaned. All of the solvent used evaporates.
These emission points were evaluated by the Agency to determine
their emission potential and possible control strategies. Industry-wide
HAP emissions from packaging and labeling were estimated as 3.4 Mg/yr
(3.7 tons/yr), those from tank cleaning were estimated as 140 Mg/yr
(154 tons/yr), and those from exterior surface cleaning were estimated
as 95 Mg/yr (104 tons/yr). No sources in the source category that
perform these operations are controlling their emissions. Thus, the
MACT floor is represented by a no-control level.
l. Use of non-HAP solvents. Some solvents used by the area sources
in this source category are currently not listed as HAP under section
112(b), and as such are not regulated under this standard. These
solvents include tetrahydrofuran, cyclohexanone, and acetone. Acetone
is used for those magnetic tape manufacturing operations that involve
coating a magnetic strip on a paper substrate, and is not suitable for
coating that involves a plastic substrate. Currently, the Agency is
developing a methodology to assess whether non-listed chemicals should
be considered for addition to the list of hazardous air pollutants.
Tetrahydrofuran, cyclohexanone, and acetone may become candidates for
this process. Therefore, the Agency is not requiring that sources
switch operations so that these non-HAP solvents are used. However, as
the compounds are not currently listed in section 112(b), sources using
and emitting these compounds and not emitting HAP compounds at a major
source level are not subject to the proposed standards.
The proposed standards also do not preclude the use of water-based
coatings. No existing sources are known to use water-based coatings.
Therefore, they were not considered in setting the MACT floor. There
does not appear to be a strong interest in their use in the magnetic
tape manufacturing industry. Industry representatives have indicated
that changing solvent formulation would likely involve changing most of
the other coating components and the coating equipment. This would
require extensive research and development, which could take years.
Furthermore, given the fact that little work has been done in
formulating water-based coatings for use in magnetic tape manufacturing
operations, it is unlikely that water-based coatings would be
sufficient to comply with either the proposed standard or the NSPS for
this industry. (See related discussion on the selection of the format
of the standards in section VI.F.)
2. Regulatory Alternatives Considered
When determining the MACT floor for the affected source, the Agency
evaluates more stringent regulatory alternatives that may be feasible.
For this source category, two regulatory alternatives have been
evaluated. These are summarized in table 3. The first alternative is
the MACT floor, as discussed above. The additional requirements of
regulatory alternative II (RA II) include the implementation of a leak
detection and repair program to control equipment leaks and a work
practice requirement for cleaning activities.
Table 3.--Regulatory Alternatives
----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
HAP emission points
-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
Cleaning activities
Reg Mix preparation ------------------------------------------------------------
alt. Storage tanks equipment Coating operation Waste handling Wastewater Condenser vents Piping leaks Flushing of fixed Particulates
Housekeeping Removable parts lines
----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
I..... 95 percent HAP 95 percent HAP 95 percent HAP 95 percent HAP 99 percent HAP 95 percent HAP No control........ None.............. 75% freeboard Closed system or Enclosed transfer
removed. removed. removed. removed. removal or 50 ppmw removed. ratio. vent to control. of particulates.
HAP outlet
concentration.
II.... 95 percent HAP 95 percent HAP 95 percent HAP 95 percent HAP 99 percent HAP 95 percent HAP LDAR program...... Use closed 75% freeboard Closed system or Enclosed transfer
removed. removed. removed. removed. removal or 50 ppmw removed. containers for ratio. vent to control. of particulates.
HAP outlet collecting and
concentration. dispensing
cleaning solvent.
----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
The LDAR program evaluated for this source category actually
involves both equipment modification and routine inspection and
monitoring. The equipment found in this source category that would be
subject to such a program includes valves, pumps, connectors, pressure
relief devices, open-ended lines, and sampling connection systems. The
program evaluated for these standards is analogous to the one required
by the negotiated regulations proposed in subpart H of the hazardous
organic NESHAP (see 57 FR 62628). Under this program, leaks from open-
ended lines, sample connections, and pressure relief valves are
eliminated through certain equipment modifications. Emission reductions
for pumps, connectors, and valves are achieved through the LDAR program
that involves monthly, annual, and quarterly inspections, respectively.
During the inspections, a portable hydrocarbon detection device is used
to determine whether the fitting is leaking. A leak is defined
differently for each piece of equipment, ranging from 500 to 10,000
ppmv hydrocarbon. The program allows for reduced monitoring frequency
if certain criteria are met. If a leak occurs, the fitting must be
repaired or replaced. Although the LDAR program is not being used in
the magnetic tape industry, the Agency considered it technically
feasible for controlling equipment leak emissions from magnetic tape
operations. The LDAR program is used in chemical manufacturing
facilities, and the same types of fittings that are present in those
facilities are present in magnetic tape operations.
The other control technique that is included in RA II is an
equipment standard to control emissions from general cleaning
activities. This work practice would require that closed containers be
used for dispensing and collecting cleaning solvent. This would prevent
solvent emissions from open containers of cleaning solvent that are
associated with cleaning operations. Some facilities in the magnetic
tape source category have reported using closed containers for
dispensing cleaning solvent. Information on the specific
characteristics of the containers was not reported, but one type of
container that is available is a spring-loaded can that delivers
solvent to a mesh surface at the top of the can only when a rag is
pressed to the mesh. Although some solvent emission reduction would be
expected from using these containers, the control level achieved by the
median of the five best performing sources is zero. Thus, this control
technique cannot be included as a MACT floor level control technique.
It is, however, considered with RA II as a control technique that is
more stringent than the floor.
As discussed in the selection of the MACT floor for existing
sources, there are sources in the industry that capture coating
operation emissions in a total enclosure and vent the emissions to an
incinerator. If the total enclosure meets the Agency's criteria and the
incinerator is properly operated, an overall efficiency of 98 percent
may be achieved. (One source that was subject to the NSPS for this
industry and operates an incinerator is estimated to achieve a 98-
percent control level.) The Agency considered whether to include a 98-
percent control requirement based on incineration as a regulatory
alternative more stringent than the MACT floor. Such an alternative may
eliminate the carbon adsorption systems and condensers currently being
used to control and recover the solvent for reuse in the coating
operation, because these systems may not be able to routinely achieve a
98-percent control efficiency. Solvent recovery is an in-process
recycling operation which, although not pollution prevention, is very
desirable (see discussion of pollution prevention in section VI.E.).
The reuse of the solvent by the industry results in a lower overall
consumption of solvent. In turn, the negative impacts from the
production of solvent are reduced. Therefore, there are both
environmental and cost benefits of solvent recovery. For these reasons,
the Agency decided not to include thermal incinerators as a separate
regulatory alternative for the magnetic tape manufacturing industry.
The Agency is interested in receiving comments on this proposed
approach.
There are other emission points at magnetic tape manufacturing
facilities that were evaluated for possible control strategies beyond
the floor. These points include packaging and labeling, cleaning of
tanks, and cleaning of fixed exterior surfaces. The packaging and
labeling emission point was evaluated to determine if non-HAP solvents
could be used. Solvent substitution was considered the only technically
feasible control technique to reduce HAP emissions from packaging and
labeling. However, after conversations with vendors who supply the inks
to industry, it was concluded that no non-HAP solvents were available.
Given the low HAP emissions from this emission point (3.4 Mg/yr total
from two sources) and the absence of any control options, it has not
been included for control in RA II.
Several control strategies were evaluated for controlling emissions
from the cleaning of tanks and fixed exterior surfaces. The first
strategy evaluated involved installing a total enclosure around the
emission source and directing emissions from the enclosure to the
existing add-on control device. This strategy was determined not to be
technically feasible because the high volume, low concentration streams
cannot be controlled by adding them to the other solvent-laden air that
is being controlled by the existing control device. A second strategy
that was evaluated involved using separate control devices particularly
suited for high volume, low concentration streams for controlling these
emission points. The Agency's analysis indicated that the cost
effectiveness of such an option would be very high, exceeding $14,500/
Mg HAP ($13,100/ton HAP) for tank cleaning. The cost effectiveness for
controlling emissions from fixed exterior surface cleaning has not been
quantified. However, it would be even higher than tank cleaning because
the capital cost of control is comparable to that for tank cleaning and
the emission reduction is even lower. (The estimate of nationwide HAP
emissions from tank cleaning is 140 Mg/yr; for exterior surfaces it is
95 Mg/yr.) Finally, the use of other cleaning agents was evaluated as a
potential control strategy. Non-HAP solvents were also determined not
to be technically feasible in all cases because the cleaning solvent
used for these emission points must be compatible with the solvents in
the coating mix. Also, as was discussed in section VI.C.1., the
substitution of the non-HAP solvents common to this industry is not
being encouraged because of the lack of data on their toxicity. The use
of soap and water was examined but was not able to clean adequately in
most cases. There is research under way that examines the use of high
pressure water to clean vessels in other industries, like the
pharmaceutical industry. There is also ongoing research to examine new
construction materials for vessels to make them easier to clean.
Although these may lead to improvements in the future, this research
was too preliminary to include in a regulatory alternative for the
magnetic tape industry. Thus, after evaluating potential control
strategies for tank cleaning and cleaning of fixed exterior surfaces,
the Agency did not include in RA II any alternative beyond the general
cleaning work practice described in the beginning of this section.
The Agency is currently developing a document describing
alternative control techniques (ACT) for controlling VOC emissions from
solvent used for cleaning operations. Some of these control techniques
may be appropriate for controlling HAP emissions. One of the techniques
evaluated in the ACT requires that a source develop a solvent
accounting system that tracks the usage and disposal of cleaning
solvent throughout a manufacturing facility. A program to test
alternative cleaning solvents may also be implemented. The results of
the ACT are not yet finalized and therefore have not been fully
evaluated in terms of their applicability to this source category.
State and local regulatory agencies that are interested in using this
system to control emissions from cleaning should notify the Agency to
keep apprised of the status of the ACT study.
3. Impacts of the Regulatory Alternatives
For each of the regulatory alternatives, environmental, energy,
cost, and economic impacts were estimated. The impacts associated with
RA I were presented in Section V. These impacts and the impacts
associated with RA II are summarized in table 4. The source of the
environmental, energy, cost, and economic impacts were also discussed
in section V. Therefore, the same discussion is not repeated here, but
impacts are briefly summarized.
Table 4.--Environmental, Energy and Cost Impacts of the Two Regulatory Alternatives on Existing Major Sources
--------------------------------------------------------------------------------------------------------------------------------------------------------
Reduction Secondary air pollution emissions, Mg/yr (ton/yr)
in -------------------------------------------------------
Reduction in particulate Incremental Incremental
solvent HAP HAP solvent HAP solid waste
Reg. Alt.a emissions in air emissions emissions in generated
from baseline, in air from PM NOx CO SOx wastewater over
Mg/yr (ton/yr) baseline, over baseline, baseline, Mg/
Mg/yr (ton/ Mg/yr (ton/yr) yr (ton/yr)
yr)
--------------------------------------------------------------------------------------------------------------------------------------------------------
I................................... 2,080 (2,300) 0.27 (0.3) 1.3 (1.4) 4.1 (4.4) a Total Annual Annual reporting and Total
Natural Steam Electricity Total capital control compliance recordkeeping annual
gas investment costs costs costs costs
I.............................. 70 (65) 20,160
(19,125) 600 (570) 20,830 (19,760) 2,263,640 174,240 115,640 110,240 400,120
II............................. 70 (65) 20,160
(19,125) 600 (570) 20,830 (19,760) 2,268,440 2,528,910 115,640 110,240 2,754,790
Difference between RA I and RA
II............................ 0 0 0 0 4,800 2,354,670 0 0 2,354,670
aFor a description of the regulatory alternatives, refer to Table 3.
a. Environmental impacts. In regard to primary air pollution
impacts, RA II would reduce solvent HAP emissions from existing major
sources by approximately 2,470 Mg/yr (2,720 tons/yr), which is an
additional decrease of 380 Mg/yr (420 tons/yr) over RA I. The
particulate HAP emission reduction for RA II is the same as it is for
RA I because RA I requires the use of the most stringent particulate
HAP control techniques available.
There are no additional secondary pollutant emissions for RA II
because the additional requirements have little or no energy impacts.
The LDAR program requires monitoring of pipe fitting emissions using an
electronic device. The use of closed containers is a work practice that
will only require the purchase of suitable containers. Likewise, there
are no additional wastewater discharges associated with RA II as
compared to RA I because there are none associated either with the LDAR
program or with the use of closed containers for dispensing and
collecting cleaning solvent. No incremental solid waste impacts are
associated with RA II.
b. Energy impacts. The energy impacts associated with RA I and RA
II are also presented in table 4. There are no additional energy
requirements associated with RA II as compared to RA I. The electricity
requirements of the electronic monitoring device required for an LDAR
program are considered negligible.
c. Cost impacts. The costs associated with RA I and RA II are
presented in table 4. The total annual cost of RA II is estimated to be
$2,754,790/yr, which includes the total annual control cost, the total
annual compliance cost, and the annual reporting and recordkeeping
cost. These two latter costs are the same as for RA I because the
compliance, reporting, and recordkeeping associated with an LDAR
program is incorporated into the LDAR annual cost. The industry-wide
cost effectiveness of RA II is approximately $1,120/Mg ($1,010/ton
HAP). The incremental cost effectiveness of RA II compared to RA I is
$6,100/Mg ($5,540/ton).
d. Economic impacts. An analysis was conducted to assess the
economic impacts associated with RA I and RA II. Price, output, and
employment impacts were evaluated on a facility-specific basis as well
as on an industry-wide basis. A worst-case scenario was used to
calculate the facility-specific impacts.
For RA I, the facility-specific impact calculations indicated that
in order for each facility to recover its control costs fully, a
minimum price increase of 0 percent would be required of some
facilities while a maximum price increase of approximately 5 percent
would be required of the marginal facility. Of the 13 facilities for
which impacts were calculated, 4 facilities were predicted to be
required to increase their prices by approximately 1 percent or
greater.
However, the analysis recognized that some facilities may be able
to absorb a portion of their increased costs. Therefore, an additional
analysis was conducted for the 4 facilities expected to experience
price increases of approximately 1 percent or greater. An examination
of the regulation's effect on the facilities' net earnings and capital
availability indicated that one facility would be significantly
impacted. This facility has been identified as a small business.
The impact that RA I would have on industry output and employment
is expected to be small. The magnetic tape industry is expected to
experience a reduction in output of approximately 0.1 percent. Assuming
a one-to-one relationship between output and employment, the industry
can also be expected to experience a similar reduction in employment.
For RA II, the facility-specific impact calculations indicated that
in order for each facility to recover its control costs fully, a
minimum price increase of approximately 0 percent would be required of
some facilities while a maximum price increase of approximately 6
percent would be required of the marginal facility. Of the 13
facilities for which impacts were calculated, 4 facilities were
predicted to be required to increase their prices by approximately 1
percent or greater. An additional analysis of RA II's impact on these
facilities' earnings, net income, and capital availability indicated
that these 4 facilities would be significantly impacted.
The economic analysis also examined the effect of RA II on industry
output and employment. The industry is expected to experience a 0.7-
percent reduction in output as a result of implementing RA II. Since a
one-to-one relationship between output and employment is assumed, the
industry is also expected to experience a similar reduction in
employment.
The results of the economic impact analysis indicate that
implementation of the proposed NESHAP should not adversely affect the
magnetic tape manufacturing industry, the economy, competition, or any
other economic concerns.
4. Selection of MACT
The Administrator is proposing that MACT for existing magnetic tape
operations be set at RA I, the MACT floor. In deciding whether to
require RA II, which is more stringent than the floor, the additional
environmental, energy, cost, and economic impacts must be evaluated.
These impacts are presented in section VI.C.3.
There are no additional secondary pollutant, wastewater, solid
waste, or energy impacts associated with RA II that would prevent the
Administrator from choosing this alternative over RA I. The
implementation of RA II would result in an additional HAP emission
reduction of approximately 385 Mg/yr (420 tons/yr). The additional
annual cost associated with this emission reduction is estimated as
$2,754,796/yr. Thus, the incremental cost effectiveness between RA I
and RA II is $6,100/Mg ($5,540/ton). The Administrator is proposing
that the costs associated with implementing RA II at magnetic tape
operations are unreasonable compared to the incremental emission
reductions that result. The primary source of emissions at a magnetic
tape manufacturing operation is associated with the coating operation,
and this emission point will be highly controlled by RA I. In fact, at
baseline conditions, industry-wide equipment leak emissions represent
10 percent of total HAP emissions, compared to 45 percent associated
with the coating operation, 19 percent associated with mix preparation,
and 17 percent associated with cleaning activities. The Administrator,
therefore, is proposing RA I as the basis of the standards for existing
sources.
D. Selection of Basis and Level of the Proposed Standard for New
Sources
1. Selection of the MACT Floor and Regulatory Alternatives
The MACT floor for new sources is based on the emission control
that is achieved in practice by the best controlled similar source. The
MACT floor for new sources is therefore the same as the MACT floor for
existing sources for each of the emission points because, as explained
in the previous section, these control technologies were the highest
level of control found in the magnetic tape industry. Likewise, the
same regulatory alternatives that were evaluated for existing sources
were evaluated for new sources.
One existing source in the industry is known to capture coating
operation emissions in a total enclosure and vent the emissions to an
incinerator. However, for the same reasons cited in section VI.C.2. in
the discussion of the regulatory alternatives considered for existing
sources, the Agency is not proposing incineration over solvent recovery
techniques as the basis for the MACT floor for new sources.
2. Impacts of the Regulatory Alternatives
Model magnetic tape operations (model lines) were created to
estimate the impacts of the regulatory alternatives on new sources. The
term model line is being used to describe a new or modified plant with
one coating line, or an existing plant that adds a new coating line. As
discussed in section II, the latter case is the one that is likely to
occur in this industry; new plants are not expected. Further, existing
plants are expected to expand capacity by adding only one coating line
at a time. A coating line by necessity has other operations such as
mixing, solvent storage, and cleaning associated with it. Therefore,
the ``model lines'' defined for this analysis include not only the
coating operation, but the ancillary operations such as mix preparation
equipment, storage tanks, waste handling devices (at larger
facilities), particulate transfer operations, and cleaning activities.
A summary of the emission points associated with model lines is
provided in Table 5. The logic is that if a coater and drying oven
(i.e., a line) were installed at a new plant or added to an existing
facility, all of the ancillary equipment would be required. For
example, at an existing plant, additional storage capacity or mix
preparation equipment may be required. This is a conservative
assumption, but one that estimates worst-case emission impacts.
Five model lines representing three sizes--small, medium, and
large--have been selected to characterize new or modified sources in
the industry. A small model line uses less than 23.5 Mg/yr (26 tons/yr)
of HAP to make applied coatings. (Applied coatings are those magnetic
coatings that are eventually applied to the base substrate at the
coater.) A medium model line uses an average of 64 Mg/yr (71 tons/yr)
of HAP to make applied coatings. A large model line uses an average of
641 Mg/yr (705 tons/yr) of HAP to make applied coatings.
The five model lines are further described as: (1) A small model
line (ML-1);
(2) A medium model line built without concurrent construction of a
solvent HAP control device (ML-2A);
(3) A medium model line built concurrently with a solvent HAP
control device (ML-2B);
(4) A large model line built without concurrent construction of a
solvent HAP control device (ML-3A); and
Table 5.--Summary of Emission Points for Model Lines
------------------------------------------------------------------------
Model line
Emission point --------------------------
Small Mediuma Largea
------------------------------------------------------------------------
Storage tanks................................ * * *
Mix preparation equipment.................... * * *
Equipment leak emissions from piping from mix * * *
room to coating operation.
Coating operation............................ * * *
Equipment leak emissions from solvent * * *
recovery operations.
Waste handling............................... * * *
Packaging/labeling........................... * * *
Cleaning activities.......................... * * *
Particulates................................. * * *
Wastewater treatment......................... * * *
Condenser vents in solvent recovery.......... * * *
------------------------------------------------------------------------
aIncludes lines that are built with and without concurrent construction
of a control device.
Note: `*' indicates emission point is included in model line.
(5) A large model line built concurrently with a solvent HAP
control device (ML-3B).
Model lines are intended to describe new sources that would be
found in the source category at baseline conditions, i.e., in the
absence of NESHAP. Because newly constructed lines are subject to the
NSPS for the industry, the baseline conditions of the model lines
incorporate control devices or methods required by the NSPS. This means
that the small line would be uncontrolled, but medium and large lines
may already be controlling their mix preparation equipment, and would
at least be controlling the coating operation (see discussion of NSPS
requirements in section III). The model line emission points that are
not controlled at baseline but that would be controlled under RA I or
RA II include storage tanks, mix preparation equipment (ML-1, ML-2A,
and ML-3A), waste handling devices, and equipment leaks.
In order to estimate the impact of the NESHAP on new sources, the
number of new sources needs to be projected. As was discussed in
section II, no new plants are expected to be built in this source
category. However, six new lines are expected to be added at existing
facilities over the next 5 years. Such situations are represented by
ML-1, ML-2A, and ML-3A (building a new line but not concurrently
constructing a control device). Because ML-2B and ML-3B are more
typical of new plants, these model lines are not used in the impact
calculations. The sizes of the new lines can also only be projected.
For the purposes of this analysis, the six new lines are projected to
have the same size mix as the existing sources in the source category.
Based on the solvent usage designations identified above, 66 percent of
the existing plants have lines that are large, 26 percent have lines
that are medium, and 8 percent have lines that are small. To estimate
impacts for new sources, this is roughly equal to four large model
lines, 1 medium model line, and 1 small model line. The impacts
discussed below incorporate this assumption. For a discussion of
impacts on a model line basis, refer to chapter 7 of the BID (see
ADDRESSES).
a. Environmental impacts. As with existing sources, the
environmental impacts of the regulatory alternatives on new sources
include primary and secondary air pollution impacts, wastewater
impacts, and solid waste impacts. All of these impacts are summarized
in table 6.
Table 6.--Impacts for New Sources
--------------------------------------------------------------------------------------------------------------------------------------------------------
HAP emission Secondary pollutant emissions, Mg/ Wastewater Energy requirements, GJ/yr
reduction yr (ton/yr) ------------------------------ (10\6\ Btu/yr)
from ------------------------------------- HAP -----------------------------
Reg. alt. baseline Mg/ Discharge emissions,
yr (tons/ PM SOx NOx 10\3\ L/yr Mg/yr (ton/ Electricity Steam
yr)a (10\3\ gal/yr) yr)b
--------------------------------------------------------------------------------------------------------------------------------------------------------
I........................................ 141 (155) 0.4 (0.5) 5.4 (6) 1.3 (1.4) 1,024 (271) 0.06(0.05) 33 (31) 6,430 (6,100)
II....................................... 194 (213) 0.4 (0.5) 5.4 (6) 1.3 (1.4) 1,024 (271) 0.06 (0.05) 33 (31) 6,430 (6,100)
--------------------------------------------------------------------------------------------------------------------------------------------------------
aThe reduction in particulate HAP emissions is the same for each alternative: 94 percent.
bThese emissions are to the wasterwater; they are not air emissions.
The HAP emission reduction achieved with RA I is estimated to be at
least 141 Mg/yr (155 tons/yr). As indicated in Table 6, RA II does not
provide any additional particulate HAP emission reduction beyond RA I
because the control requirements are the same. The additional solvent
HAP emission reduction associated with RA II (53 Mg/yr [58 tons/yr])
are from implementing the LDAR program.
Secondary pollutants (PM, NOx, and SOx) will be emitted
from model lines as a result of the combustion of fuel oil in the
boiler used to produce steam. (It is assumed that all of the model
lines use carbon adsorption systems as control devices because this is
the predominant control device used by the major sources in the
industry.) For ML-1, the fuel oil consumption is a result of a new
control device required to meet RA I and RA II. For the other model
lines, the fuel oil consumption is incremental over baseline, resulting
from controlling additional emission points. As with the existing
sources, the magnitude of the estimated quantity of secondary emissions
(7.1 Mg/yr [7.9 tons/yr]) is much less than the estimated HAP emission
reduction.
For the same reasons explained for existing sources, there will
also be incremental wastewater discharges over baseline conditions from
the model lines under RA I and RA II. Small lines are assumed to
dispose of wastewater offsite because it is unlikely that a small
operation would perform on-site wastewater treatment. Thus, there is no
discharge. The waterborne HAP emission levels presented in Table 6
assume a 50-ppmw discharge limit for HAP compounds. As indicated in
this table, the quantity of HAP discharged to the wastewater is small.
The final environmental impacts associated with the model lines are
solid waste impacts. All model lines except for the small model line
are currently assumed to use fixed-bed carbon adsorption systems to
meet the requirements of the NSPS (baseline conditions for new lines).
As with existing sources, it is assumed that the control of additional
emission points would not decrease the carbon life. Thus, there are no
solid waste impacts from medium and large lines. Overall impacts are a
result of any new small model lines.
b. Energy impacts. The estimated additional steam requirement of
new lines that would result from implementing the regulatory
alternatives are presented in table 6. This table also includes the
additional electricity requirements for new lines. As explained for
existing sources, RA I and RA II have the same energy impacts because
the higher level control options associated with RA II have no energy
requirements.
c. Cost impacts. There are some difficulties inherent in estimating
the cost of regulatory alternatives for new sources because the ``new''
sources are expected to be new coating operations and ancillary
equipment installed at existing plants. There are, therefore, many
factors that would influence the cost to meet the proposed standards.
Factors that vary from plant-to-plant include the size of the plant,
the existing level of control, the type of control device used, the
percentage of total solvent used that is HAP, the extent of magnetic
tape operations (as compared to other manufacturing operations) at a
plant, the percentage of HAP in the coating mix, and process
differences such as the type and amount of equipment in the plant
(important in assessing the appropriateness of LDAR). Some of these
factors have been accounted for in developing the model lines, but to
account for all differences among the plants in this source category
would be impossible.
Despite the difficulties in estimating the cost of regulatory
alternatives on new sources, such an analysis is necessary to determine
the extent of control that is appropriate for these sources. Therefore,
a range of the incremental cost-effectiveness values that would result
if RA II were applied instead of RA I has been estimated by
incorporating as many factors as was reasonably possible into the model
plant analysis. The range of cost-effectiveness values was calculated
to determine the range of cost impacts that may actually be encountered
in the industry. In addition to estimating the cost impacts on the
model lines previously described, costs were estimated assuming that
the models used incinerators instead of carbon adsorption systems. This
permutation accounts for the fact that some sources in the industry
(both small and large) have elected to use incineration over solvent
recovery technologies. The models are still limited in that they assume
that 100 percent of the solvent used are HAP, and that a facility is
performing only magnetic tape manufacturing operations.
If it is assumed that a carbon adsorption system is used to comply
with RA I, the total annual cost is estimated to be $349,360/yr. This
cost includes control costs, compliance costs, and reporting and
recordkeeping costs. The associated cost effectiveness is $2,470/Mg
($2,250/ton). For RA II, this cost increases to $483,080/yr, with a
cost effectiveness of $2,500/Mg ($2,270/ton). The incremental cost of
applying RA II over RA I is approximately $2,550/Mg ($2,320/ton). If an
incinerator is used to comply with RA I, the total annual cost is
estimated to be $270,367 including control, compliance, and reporting
and recordkeeping costs. The associated cost effectiveness is $1,910/Mg
($1,740/ton). Under RA II, the annual cost increases to $362,847, with
an average cost effectiveness of $2,370/Mg ($2,150/ton). When
incineration is the control technique used by model lines, the
incremental cost of applying RA II over RA I is approximately $7,590/Mg
($6,900/ton).
3. Selection of MACT
As with existing sources, in evaluating MACT for new sources the
Administrator looks at the emission reductions, costs, economic
impacts, and other environmental and energy impacts. As discussed in
the previous section, cost impacts were calculated considering that
either a carbon adsorption system or an incinerator could be used.
However, as was discussed in section VI.D.2, the environmental and
energy impacts are based on the use of a carbon adsorption system
because this type of system is the most commonly used in the industry.
Based on the environmental impact estimates calculated for existing
sources, other environmental impacts (i.e., secondary pollutants,
wastewater and solid waste) are not substantial compared to the HAP
emission reduction that is achieved with either regulatory alternative,
regardless of the control technology used. Therefore, as was the case
for existing sources, the basis of the decision to regulate new sources
with RA I or RA II is based on the cost impacts and emission
reductions.
The cost analysis indicates that, depending on the type of control
device used and the size of the plant, the incremental nationwide cost
effectiveness of applying RA II instead of RA I is approximately
$2,550/Mg if carbon adsorbers are used and $7,590/Mg if incinerators
are used. On a per-line basis, however, the incremental cost
effectiveness ranges from $2,400/Mg to almost $60,000/Mg.
The incremental cost effectiveness of applying RA II over RA I will
vary depending on the type of plant at which the new line is located.
An analysis of the estimated incremental cost effectiveness of RA II
over RA I for existing sources also indicates a wide range in values.
For some existing facilities, the incremental cost effectiveness is
low, less than $100/Mg. For others, however, it is very high, exceeding
$100,000/Mg. As was stated in Section VI.C.3, the industry-wide
incremental cost effectiveness is $6,100/Mg. The reasons for the
variation in the incremental cost effectiveness for existing sources
are not so obvious that distinct subcategories would be possible. For
example, the incremental cost effectiveness is not consistently high or
low based on the size of the facility or the type of control device
used at a plant. The quantity of HAP that is used at a plant relative
to the total solvent used affects the incremental cost effectiveness,
as does the extent of magnetic tape manufacturing operations at a
facility (i.e., other products may be manufactured). There are no clear
distinctions, however, to indicate when RA II is cost-effective and
when it is not; it is highly source-specific.
Based on the costs and emission reductions associated with RA I and
RA II, and the potentially high incremental cost effectiveness of
applying RA II over RA I, the Administrator is proposing that MACT for
new sources should be RA I, which is also the proposed MACT for
existing sources. As with existing sources, the Agency does not feel
that the additional cost of RA II is justified given the small
incremental emission reduction that results.
E. Pollution Prevention Considerations
The Pollution Prevention Act of 1990 establishes the following
environmental management hierarchy as national policy:
(1) Pollution should be prevented or reduced at the source wherever
feasible;
(2) Pollution that cannot be prevented should be recycled in an
environmentally safe manner wherever feasible;
(3) Pollution that cannot be prevented or recycled should be
treated in an environmentally safe manner wherever feasible; and
(4) Disposal or other release into the environment should be
employed only as a last resort and should be conducted in an
environmentally safe manner.
The Pollution Prevention Act considers ``source reduction'' as a
fundamental aspect of pollution prevention. Source reduction is any
practice that reduces the amount of any hazardous substance entering
the waste stream or otherwise released into the environment prior to
recycling, treatment, or disposal. Practices such as recycling, energy
recovery, treatment, and disposal are not considered pollution
prevention measures under the Pollution Prevention Act. However, as
noted above, recycling conducted in an environmentally safe manner is
still desirable.
The proposed rule contains one source reduction element and
encourages environmentally beneficial recycling. Some source reduction
is achieved by requiring that existing and new sources maintain a 75-
percent freeboard ratio in wash sinks used for cleaning removable
parts. This control technique limits emissions by requiring that a
lower level of solvent be kept in the sink. For example, a facility
previously may have filled the wash sink to capacity; now, the sink
would only be filled about one-quarter of that amount, but the same
level of cleanliness would still be achieved. Solvent emissions have
thus been reduced by reducing solvent usage. It is estimated that
solvent emissions are reduced by 88 percent compared to traditional
methods of cleaning parts in wash sinks. The extent to which usage is
reduced will vary from plant to plant; some sources may wash parts more
frequently even though the amount of solvent used during each cleaning
is reduced. The trend indicated by existing sources maintaining a
freeboard ratio, however, is that overall solvent usage will be
reduced.
Although not considered source reduction, solvent recycling is a
common practice in this industry and is further encouraged by the
proposed rule. Many facilities in this source category use solvent
recovery devices such as carbon adsorption systems or condensers to
control air emissions. The solvent controlled by these devices is
subsequently collected and distilled so that it can be reused in either
the coating or cleaning process. This is a very beneficial process both
to industry and the environment. Industry benefits because any solvent
that is recycled is profitable; it is solvent that they would otherwise
have to purchase. Also, less solvent enters the waste stream because
less solvent is used. An environmental benefit is that less consumption
of solvent by this industry means less production of solvent and the
negative environmental impacts that go along with solvent manufacturing
processes.
It has also been determined that there are negligible cross-media
impacts from the solvent recovery devices in this industry. Any
wastewater that results is treated in a steam stripper prior to
discharge to a POTW. The solvent recovered from stripping is collected,
distilled, and reused. The other secondary impacts from control
operations have been calculated and are very small compared to the HAP
emission reduction that is achieved with the devices. Finally, with
regard to carbon adsorption systems, the carbon is regenerated onsite
until its useful life is over, approximately 5 years. The amount of
carbon disposed by a large facility (worst case) is small compared to
other solid waste generators and is estimated as 8,000 pounds every 5
years. Facilities have reported that the spent carbon is a nonhazardous
solid waste that can be sent offsite for reactivation when its useful
life is over.
F. Selection of Format
The emission points to be covered by the proposed standards
include:
(1) The solvent storage tanks;
(2) The mix preparation equipment;
(3) The coating operation(s);
(4) The waste handling devices;
(5) The particulate transfer operations;
(6) The wash sinks for cleaning removable parts;
(7) Cleaning involving the flushing of fixed lines;
(8) The wastewater treatment systems; and
(9) The condenser vents in the solvent recovery area except the
vent on a condenser that is the primary air pollution control device.
The proposed standards require an overall HAP control efficiency of
95 percent for control of emissions from each of the following sources:
Solvent storage tanks, mix preparation equipment, coating operation(s),
waste handling devices, and condenser vents in solvent recovery.
Sources using incineration can alternatively meet an emission limit of
20 ppmv HAP outlet concentration. For wastewater, 99 percent of the HAP
present must be removed, or the total HAP outlet concentration must not
exceed 50 ppmw. Emissions from wash sinks must be controlled by 88
percent. Equipment standards would be required to control emissions
from particulate transfer operations and the cleaning of fixed lines by
flushing. The rationale for selecting the percent efficiency format is
provided below. The rationale for selection of the emission limit for
wastewater treatment and wash sinks, the alternative emission limit for
incinerators, and for the equipment standards are presented in section
VI.G.
There were several formats that were considered for the proposed
standards, including a concentration limit (ppm), a mass emission rate
per volume of coating or coating solids (lb/gal or lb VOC/lb solids), a
process emission rate (lb emitted/unit produced), or a percent control
efficiency. The primary reason for choosing percent reduction as the
format of the standards is the fact that this format assures a
consistent requirement for all plants and allows plants flexibility in
the method selected for emission reduction. The NSPS also use a percent
reduction format. To maintain consistency between the NSPS and NESHAP,
it is reasonable to choose the same format for the NESHAP.
A concentration format is not recommended in all cases because it
does not always result in equivalent control among all facilities. For
example, a facility with a high inlet loading to the control device
would be controlling more total emissions than a facility with a lower
inlet loading. The format of mass per unit of production (e.g., kg/m\2\
of tape coated) is not recommended because it would result in different
levels of control at different plants due to variations in coating
thickness and coating solvent content. The format of mass of emissions
per volume of coating or per mass of coating solids is also not
recommended because of the variety of coating formulations used. The
above formats are also not recommended because recent HAP emission data
are not available for this source category. As such, there is no
technical basis for establishing a value for the pounds of HAP emitted
per hour, per coating solids, or per unit produced. Also, given the
fact that this industry uses solvents that are both HAP and non-HAP and
each operation differs in the percent of solvent used that is HAP, it
would be very difficult to establish one HAP emission rate or HAP
concentration for the entire industry. Therefore, a percent reduction
format is proposed.
One undesirable aspect of the percent reduction format is that it
does not credit improvements in the coating formulation or in process
operations that could potentially be pollution prevention measures. For
example, reduction in the HAP content of the coating through the use of
water-based coatings or a reduction in the amount of HAP applied per
unit of tape manufactured would not be credited toward compliance. This
might discourage development of water-based coatings or optimization of
processes from a pollution prevention standpoint. One possible solution
to the problems inherent with a percent reduction format is to specify
a coating limit (e.g., pounds of HAP per gallon) that is an acceptable
alternative to the percent reduction proposed. The NSPS for this
industry have a similar provision; to date, no source subject to the
NSPS has complied with the rule by using a low-VOC coating. The Agency
requests comments on the feasibility of allowing a coating limit as an
equivalence to compliance with the proposed percent reduction in HAP
emissions, as well as data that would suggest the specific coating
limit that would be equivalent with the proposed MACT requirements.
G. Selection of Emission Limits, Work Practice, and Equipment Standards
The emission limit that has been selected for controlling HAP
emissions from solvent storage tanks, mix preparation equipment,
coating operation, and waste handling devices is a HAP control
efficiency of 95 percent at each emission point. In expressing the
standards for some emission points as a 95-percent control efficiency,
the Agency is relying on past tests and proven performance that
indicate the control efficiency that is achievable with certain control
devices. For example, through tests in other industries it has been
proven that well-operated and well-maintained carbon adsorption systems
and incinerators can obtain at least 95-percent removal efficiencies.
The proposed standards allow facilities using incinerators the
alternative of achieving either the 95-percent control efficiency or an
emission limit of 20 ppmv total HAP. The 20 ppmv HAP limit is based on
the Agency's study of available incinerator technology, cost, and
energy use. The dual requirement of 95 percent or 20 ppmv limit
accounts for a fall-off of incinerator efficiency at lower inlet
concentrations. The Agency believes that a 20-ppmv HAP limit could be
reached by most incinerators with moderate adjustments.
One technical issue associated with the selection of an overall HAP
control efficiency of 95 percent that was brought up by a member of the
industry is the difficulty of achieving this efficiency at low inlet
concentrations. The concern was raised with respect to a carbon
adsorber. Typically, one common control device is used to control
emissions from the various sources at a magnetic tape operation. If the
coating operation emission point is not concurrently being directed to
the control device with the emissions from other emission points such
as the mixers and storage tanks, the inlet concentration to the control
device may be very low. For example, the inlet concentration when the
coating operation is operating may be 3,000 ppmv and an outlet
concentration of 100 ppmv could be achieved (a 96.7 percent emission
reduction). If only mix preparation equipment, solvent storage tanks,
or waste handling device emissions are being vented, the inlet
concentration may only be 200 ppmv. Even if an outlet concentration of
30 ppmv is achieved, the control efficiency is only 85 percent. The EPA
has recognized this problem for incinerators and, consequently, has
included the alternative 20 ppmv HAP emission level.
However, the proposed standards do not include special provisions
for low inlet concentrations for control devices other than
incinerators. The Agency would like comments and data on this issue.
If, based on comments received at proposal, the Agency determines that
the 95-percent control efficiency standards cannot be met at low
concentrations, the Agency is considering the following possible
solutions for the promulgated standards:
(1) Allow a longer averaging time for demonstration of compliance
(e.g., the proposed monitoring requirements identify a 3-day rolling
average for carbon adsorbers; this averaging period could be increased
to allow for some fluctuation in the percent efficiency when the
coating operation is down);
(2) Specify an alternate control efficiency for periods when the
coating operation is down; or
(3) Specify an outlet concentration for those periods when the
coating operation is down.
The Agency would also like to receive comments and any data that
may indicate an appropriate averaging time, outlet concentration, or
percent removal efficiency.
Another emission point that requires a percent removal efficiency
is the wastewater treatment system; owners or operators must remove 99
percent of the HAP in wastewater discharged from the water phase of a
carbon adsorption system using steam desorption. The percent removal
efficiency is primarily based on the analysis being carried out for the
hazardous organic NESHAP (HON) for the chemical manufacturing industry.
The proposed HON rule (see 57 FR 62628) indicated that the HAP
compounds used in the magnetic tape industry (MEK, toluene, MIBK) are
readily stripped and a 99-percent removal efficiency is proposed for
those compounds. There are no specific data for magnetic tape
operations, but industry representatives have stated that wastewater
treatment operations are likely to be 99-percent efficient. The Agency
solicits comments on this efficiency. Data would be necessary to
support any suggested efficiency requirements other than 99 percent.
The proposed standards would also allow sources to comply with the
wastewater treatment provisions of the proposed regulation by treating
the wastewater discharge from the separator in a steam stripper such
that the effluent from the steam stripper has a total HAP concentration
of less than 50 ppmw. The emission limit of 50 ppmw HAP is based on
data from two facilities that operate steam strippers that are
estimated to remove at least 99 percent of the HAP compounds present.
The total HAP concentration in the effluent from their steam strippers
was reported as 20 and 40 ppmw. These concentrations are representative
of the HAP concentration in the wastewater before it is combined with
any other on-site wastewaters (such as sanitary waste). In other rules
requiring the treatment of wastewater via steam stripping, the Agency
has selected 50 ppmw as an appropriate emission limit for compounds of
similar stripability. The data support this limit as being achievable
for this source category. The available data are too limited and too
inconclusive, however, to support a lower limit. Therefore, a HAP
concentration of 50 ppmw in the water discharge is being proposed for
this standard. The Agency requests comments on this proposed limit, as
well as any data that would support an alternate limit.
The proposed standards require that HAP emissions from wash sinks
be controlled by 88 percent. This level of control can be achieved by
maintaining a 75-percent freeboard ratio. This is the freeboard ratio
maintained by facilities in the source category currently subject to
regulatory requirements on wash sinks. An alternative method of
controlling wash sink emissions is to vent them to the common control
device; this method is also thought to be 88-percent efficient. The
emission limit identified for both control technologies is based on
industry tests that compared the quantity of HAP emissions occurring
from wash sinks both before and after controls are imposed.
The other emission points that will require control under the
proposed standards include the particulate transfer operations and
cleaning that involves the flushing of fixed lines. For these emission
points, the proposed standards are expressed as equipment standards.
Although NESHAP are normally structured in terms of numerical emission
limits, alternative approaches are sometimes necessary. In some cases,
physically measuring emissions from a source may be impossible or at
least impracticable because of technological and economic limitations.
Section 112(h) authorizes the Administrator to promulgate a design,
equipment, work practice, or operational standard, or combination
thereof, in those cases where it is not feasible to prescribe or
enforce an emissions standard. For this source category, equipment
standards have been selected for the reasons described below.
The requirement for particulate transfer operations would be an
equipment standard, requiring the installation of an enclosed transfer
device to be used when transferring chromium- or cobalt-containing
particulates. The definition of an enclosed transfer device is provided
in Sec. 63.702. An emission limit or percent control efficiency is not
feasible because HAP emissions from particulate transfer cannot
reasonably be emitted through a conveyance system designed and
constructed to capture these pollutants. Therefore, it is recommended
that this emission point be regulated by an equipment standard. There
is at least one source in the industry that does not have an enclosed
transfer device but uses fabric filters to remove particulate from the
solvent-laden air being sent to the control device. The Agency
currently has no data to suggest the feasibility of, or control
efficiency associated with, such filters. The Agency is concerned that
particulate emissions would not be sufficiently captured and delivered
to the control device. The one facility using fabric filters for
control operates within a total enclosure designed to capture gaseous
emissions. The Agency is also concerned that particulate emissions
could occur during the removal of the particulate from the filters.
Therefore, the Agency is not proposing an alternative standard based on
such a system. The Agency is interested in data that show whether the
total enclosure controls particulate emissions as well as gaseous
emissions. However, the Agency specifically requests comments on the
proposed standard for not identifying as an alternate particulate
control level an overall control efficiency that could be achieved by
capturing particulates and venting them to a control device such as a
fabric filter. Data that indicate the overall control efficiency
(capture and control) of such systems would be required to support any
suggested efficiency.
For control of emissions from flushing fixed lines, the standards
would be equipment-based, requiring that the lines be flushed using a
closed system (see description in section VI.B). Alternatively, if open
tanks are used for supply and collection, the area in which they are
located would need to be vented to a control device such that the
overall efficiency is 95 percent. Every facility in the industry that
flushes fixed lines performs the operations in one of these two ways.
An emission limitation is not appropriate because the HAP from this
operation are not emitted through a conveyance system designed and
constructed to capture these pollutants.
H. Selection of Monitoring Requirements
In accordance with paragraph (3) to section 114 of the amended Act,
enhanced monitoring of stationary sources is required to determine the
compliance status of the sources, and whether compliance is continuous
or intermittent. For most of the sources subject to the proposed
standards, initial compliance is determined through the initial
compliance test, and ongoing compliance through continuous monitoring.
The Agency has proposed the parameters to be monitored for the types of
capture and control devices now used in the industry. The value of this
parameter that corresponds to compliance with the standard is set by
the owner or operator during the initial compliance test. If future
monitoring indicates that capture or control equipment is operating
outside of the range of values established during the initial
performance test, the owner or operator is out of compliance with the
standards, except as specified for malfunctions in Sec. 63.6(e)(3) of
the General Provisions.5
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\5\Ibid.
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1. Work Practice and Equipment Standards
For equipment standards, no monitoring would be required. However,
the owner or operator is expect
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