# National Emission Standards for Hazardous Air Pollutants; Proposed Standards for Hazardous Air Pollutant Emissions From Magnetic Tape Manufacturing Operations; Proposed Rule ENVIRONMENTAL PROTECTION AGENCY > Briefs, arguments, decisions, and more. URL: https://www.frixlaw.com/law-library/documents/fr%3A94-5313 ## Record - **Collection:** Federal Register - **Document type:** Uncategorized Document - **Published:** March 11, 1994 ## Text 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. --------------------------------------------------------------------------- \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. --------------------------------------------------------------------------- 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. --------------------------------------------------------------------------- \2\Section 63.7(a)(2)(ix) of the proposed General Provisions implements this requirement. --------------------------------------------------------------------------- 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 --------------------------------------------------------------------------- \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. --------------------------------------------------------------------------- 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. --------------------------------------------------------------------------- \4\Ibid. --------------------------------------------------------------------------- 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\ [Text truncated at 120,000 characters. The full text is on the page linked above.] --- Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/fr%3A94-5313. Public record. Not legal advice.