United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Park NC 2771 1
EPA-450/3-85-029b
July 1988
Air
Magnetic Tape
Manufacturing
Industry — Background
Information  For
Promulgated Standards
                  Fin a
                  EIS

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                                          EPA 450/3-85-0295
Magnetic Tape Manufacturing Industry —
Background Information For Promulgated
                   Standards
                 Emission Standards Division
              U.S. ENVIRONMENTAL PROTECTION AGENCY
                  Office of Air and Radiation
              Office of Air Quality Planning and Standards
              Research Triangle Park, North Carolina 27711

                      July 1988

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This report has been reviewed by the Emission Standards Division of the Office of Air Quality Planning and
Standards, EPA, and approved for publication. Mention of trade names or commercial products is not
intended to constitute endorsement or recommendation for use. Copies of this report are available through
the Library Services Office (MD-35), U.S. Environmental Protection Agency, Research Triangle Park, North
Carolina 27711, or from National Technical Information Services, 5285 Port Royal, Springfield, Virginia
22161.

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                      ENVIRONMENTAL PROTECTION AGENCY

                           Background  Information
                                 and Final
                       Environmental  Impact Statement
                for the  Magnetic Tape  Manufacturing Industry
                                Prepared  by:
          inner
Director, Emission Standards Division
U. S. Environmental Protection Agency
Research Triangle Park, N.C.  27711

1.  The promulgated standards of performance will  limit emissions of
    volatile organic compounds (VOC) from new, modified, and reconstructed
    facilities that manufacture magnetic tape.  Section 111 of the Clean
    Air Act (42 U.S.C. 7411), as amended, directs  the Administrator to
    establish standards of performance for any category.of new stationary
    source of air pollution that ". . . causes or  contributes
    significantly to air pollution which may reasonably be anticipated to
    endanger public health or welfare."

2.  Copies of this document have been sent to the  following Federal
    Departments:  Labor, Health and Human Services, Defens.e,
    Transportation', Agriculture, Commerce, and Interior; the National
    Science Foundation; the Council on Environmental Quality; State and
    Territorial Air Pollution Program Administrators; -EPA Regional
    Administrators; Association of Local  Air Pollution Control  Officials;
    Office of Management and Budget; and  other interested parties.

3.  For additional information contact:

    Mr. Sims Roy or Mr. Gil Wood
    Standards Development Branch (MD-13)
    U. S.  Environmental Protection Agency
  .' Research Triangle Park, N.C.   27711
    Telephone:   (919)  541-5263

4.  Copies of this document may be obtained  from:

    U. S.  EPA Library (MD-35)
    Research Triangle Park,. N.C.   27711
    Telephone:   (919)  541-2777

    National  Technical  Information Service
    5285 Port Royal  Road
    Springfield,  Va.   22161

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                             TABLE OF CONTENTS
                                                                      Page
LIST OF FIGURES	     vi

LIST OF TABLES	     v1

CHAPTER 1.  SUMMARY..	    1_1

            1.1  Summary of Changes Since Proposal	    1-1
            1.2  Summary of Impacts of Promulgated Action	    1-8

CHAPTER 2.  SUMMARY OF PUBLIC COMMENTS	    2-1

            2.1  Level  of the Standard	    2-1
            2.2  Best Demonstrated Technology (BDT)	'.   2-25
                 2.2.1   Coating Operation	„	]   2-25
                 2.2.2   Mix Room	..   2-28
            2.3  Affected Facility and Modification  and
                   Reconstruction	   2-31
            2.4  Solvent Storage Tanks	[.   2-38
            2.5  Compliance Provisions	   2-39
            2.6  Reporting and  Recordkeeping  Requirements	!   2-50
            2.7  Cost and Economic Assumptions  and Impacts	   2-51
            2.8  Suspension of  the Standards	   2-70
            2.9  References for Chapter  2	   2-72

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                              LIST OF FIGURES
Figure 2-1   VOC penetration of activated  carbon  adsorption bed
               at time Tj.	    2-12

Figure 2-2   VOC penetration of activated  carbon  adsorption bed
               at time T2	    2-12

Figure 2-3   VOC penetration of activated  carbon  adsorption bed
               at time T3		    2-12

Figure 2-4   VOC penetration of activated  carbon  adsorption bed
               at time T^	,	    2-12

Figure 2-5   Typical carbon adsorption breakthrough curve	„	    2-14

Figure 2-6   Tenth adsorption cycle with new carbon	„	    2-54

Figure 2-7   Last adsorption cycle prior to carbon replacement.....    2-54





                              LIST OF TABLES
                                                                        i
                                                                       Page

TABLE 1-1   ANNUAL IMPACTS OF THE REVISED NSPS...	......,;-...     1-9

TABLE 2-1   LIST OF COMMENTERS ON PROPOSED STANDARDS OF
              PERFORMANCE FOR MAGNETIC TAPE MANUFACTURING
              INDUSTRY	     2-2

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                                 1.  SUMMARY

      On January 22, 1986, the Environmental  Protection Agency  (EPA)
 proposed new source performance standards  (NSPS) for magnetic  tape
 manufacturing facilities (51 FR 2996) under  authority of Section  111 of
 the Clean Air Act.  Public comments were requested on the proposal in the
 Federal Register.  One trade association and 14 representatives from
 11 companies commented on the proposed NSPS.  Additional information
 relevant to the issues rais.ed by the commenters was sought and obtained
 from industry, process and control equipment vendors, and local regulatory
 agencies.   This information was incorporated into the Agency's responses
 to-the comments.   The comments and responses are summarized in this
 document.   The summary of.comments and responses and the additional
 information contained in the docket that was' gathered-to supplement and
'verify the assertions made by the  commenters serve  as the basis for the
 revisions  made to the standards  between  proposal  and promulgation.
 1.1   SUMMARY OF CHANGES SINCE PROPOSAL
      In response  to public  comments and  as  a result  of EPA  revaluation,
 changes have been made in the proposed standards.  Significant  changes  are
 summarized  below.   All  changes that have  been made to the regulation  are
 explained  fully in the responses to the comments.
      Changes were  made in the level  of control required by the
 standards.   A new  survey  of  the plants in this industry indicated  that the
 primary, means  of growth  in this industry will be by modification and
 reconstruction  of  existing lines, not  construction of new lines as
 previously  predicted by the  industry.  A cost analysis of modification
 scenarios at  specific  plants  resulted  in -a change in the level of control
 required by  the standard  for modified and reconstructed coating operations
 and for most mix equipment.   If an existing coating  operation can be
                                    1-1

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demonstrated to achieve a baseline level of  control of 90  percent  or
better, the revised standard allows the coating operation  to  remain  at the
demonstrated level of control or 93 percent, whichever is  lower, after it
is modified or reconstructed.  The 90 percent  level of control can be
demonstrated by a performance test or by the alternative means of
compliance, the use of a total enclosure and a control device that is  at
least 92 percent efficient.
     If the owner or operator of a modified or reconstructed coating
operation subsequently adds a new control device, the revised standard
requires that the control device must be at least 95 percent efficient.
In addition, the owner or operator must demonstrate that the overall level
of control determined prior to installation of the new control device  is
still being achieved.  If this demonstration shows that a  higher overall
efficiency is being achieved with the new control device than was
previously demonstrated, then the coating operation must continue to meet
either this higher level of control or 93 percent, whichever is lower.
     New coating operations and existing coating operations with a
baseline control level below 90 percent before modification or
reconstruction must meet the originally proposed standard of at least
93 percent control of the applied solvent.   An annual  solvent utilization
cutoff of 370 cubic meters (m3)  (98,000 gallons [gal])  has been added.for
modified or reconstructed coating operations based on  projected equipment
needs for compliance at such facilities and the model  line parameters .and
costs developed prior to proposal.   The annual  solvent  utilization  cutoff
of 38 m  (10,000 gal)  in the proposed  standard  has been retained  for  new
coating operations.  The basis for  "annual  solvent utilization"  has been
changed for clarification from a "12-month  period" to  a "calendar year."
     The revised mix equipment standard requires  the use  of covers  alone
or covers with venting to a control  device  in the  following three circum-
stances:  (1)  when mix equipment is  modified or reconstructed;  (2)  when
new mix equipment is installed without  the  concurrent construction  of a
new control  device on  a coating  operation;  and  (3)  when the control device
that is constructed concurrently is  a condenser.   When  new  mix  equipment
is added during concurrent construction of  a new control  device  (except
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 condensers) for emissions of volatile organic compounds  (VOC)  from  a
 coating operation, covers that meet specific criteria and that are  vented
 to a 95 percent efficient control device must be used.   The wording of
 this standard has been modified to reflect more closely  the practical
 application of best demonstrated technology (BDT) for this category of mix
 equipment.   For this standard, "concurrent" means that the control  device
 is constructed within 6 months before or 2 years after the installation of
 the new mix equipment.
      The affected facility definition has been revised.   In the proposed
 standards,  the affected facility was defined as each coating operation
 with its associated mix equipment.   This definition was  selected because
 it achieved the highest level  of nrix room control  at a reasonable cost for
 the proposed level  of the  standards.   The standard  recommended for
 promulgation contains separate affected  facility definitions  for each
 coating  operation and each  piece of  mix  equipment.
      Several  changes  were made in the  definitions and  the compliance
 provisions.'  Industry representatives  requested  that EPA  provide a defini-
 tion  of  total  enclosure by  which  they  could  determine  compliance.  Total
 enclosure requirements  have been  added to the regulation,  that  limit  the
 total area  of  the natural draft  openings 'in  the  enclosure, that specify
 the minimum allowable distance between the openings  and the sources  of
 VOC,  and that  require the maintenance of an  average  face  velocity  of at
 least 3,600 meters per hour (m/h) (200 feet per minute [ft/min]) across
 the openings.  These restrictions are necessary to ensure complete
 containment of the VOC emissions from the coating operation.  However,
 flexibility has been maintained by allowing structures not meeting the
 requirements to be approved by the Administrator on a case-by-case
 basis.  Test procedures  and monitoring, recordkeeping,  and reporting
 requirements for the use of total enclosures also have  been added.
     The provisions for  demonstrating compliance with the  coating
 operation standards by a monthly material  balance (§ 60.713(b)(l))  have
 been revised to account  for VOC that  may  be  retained in the magnetic  tape
 after oven drying.  The  quantity of retained  solvent, RSj, must be
determined by the owner  or  operator by  measurement techniques  approved  by
the Administrator.  The  term "RS^1 has  been  included  in Equation 1  and  has
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been defined in § 60.711.  Other definitions  also  have  been  modified  to
clarify that the monthly material  balance  is  intended to  include  the  net
VOC actually emitted from the coating operation  in the  gaseous  phase.
Thus, all VOC (including dilution  solvent)  added at any point  in  the
process is to be included, and any VOC contained in waste coatings or
retained in the final product can  be subtracted.
     One compliance option presented in the proposed magnetic tape NSPS
allowed the use of a short-term gaseous emissions  test  to apportion the
results of a long-term  liquid material balance at  plants  with affected and
nonaffected coating lines controlled by the same solvent  recovery device.
Although comments were  requested on this compliance method at proposal,
none were received.  The EPA has since reviewed this method  and determined
that the variability in production and solvent use during a  month is too
great for gaseous proportions measured over a single short-term (3-hour)
test period to be meaningful when  applied to  a 1-month  solvent recovery
value.  Therefore, this test method has been withdrawn  as  a  compliance
method.
     The compliance provisions have been revised to  clarify  their
application to coating  operations with permanent total  enclosures.  The
test procedures provided in the regulation at proposal"  and retained'in the
final, rule include the  performance test option of measuring  both capture
efficiency and control  device efficiency; the product of  these two .values
is required to be at least 93 percent (or 90 percent for  certain modified
or reconstructed facilities).  As, proposed, this option might have been
interpreted to allow the capture efficiency of a permanent total enclosure
to be presumed to be 100 percent;  However, it is doubtful that this
theoretical capture efficiency is, ever realized in practice,  particularly
when access doors occasionally must be opened.  Therefore, this perfor-
mance test procedure has been revised to require the measurement of
capture efficiency whenever the procedure is used,  even when  a permanent
enclosure is in place.
     The alternative means of comjoliance in the proposed regulation,  the
demonstration that a total enclosure, which meets certain  work practice
and equipment requirements (or has been approved by the Administrator  on  a
case-by-case basis), and a 95 percent efficient control  device are in  use,
                                    1-4

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 has been retained in the final rule.  Plants are expected  to  select this
 alternative means of compliance because it is easier and less costly than
 the performance test method.
      The performance testing and monitoring provisions for fixed bed
 carbon adsorption systems have been revised to represent more accurately
 the performance of multibed systems.  This revision was an indirect result
 of a public comment concerning the performance of fixed-bed carbon
 adsorbers.   Performance tests are, the direct means of determining the
 compliance  status of an affected facility and serve as the basis for legal
 enforcement actions against noncomplying sources.   In contrast,  the
 monitoring  devices required by these standards serve only as indicators of
 control  device  performance to aid enforcement agencies in targeting
 inspections and performance tests toward potential  violators.  The revised
 procedures  will  ensure  that the performance test  runs and monitoring
 averaging periods will  parallel the complete  adsorption cycles of the
 •individual  adsorber vessels or the system's complete sequential  rotation
 through  the adsorption  cycles of  all  the vessels.   Use  of a testing or
 monitoring  period that  does not correspond  to  an  integral  number of actual
 adsorber vessel  cycles  or  system  rotations  could bias the results  slightly
•in'either direction.  Efficiencies  would be biased  high  if  the test run  or
 monitoring  period did not  include  the elevated emissions  typical at the
 beginning and end of a  vessel's adsorption  cycle; efficiencies would be
 biased low  if the period included a disproportionate number of these
 emission peaks.
     The performance testing  provisions for carbon adsorption systems
 included in the  standards at  proposal did not specifically index the test
 period to discrete adsorber vessel  cycles or system rotations.   Rather,
 each of  the three requisite performance test runs was required  to be a
minimum of 30 minutes duration.  While this requirement would have allowed
the performance test runs to correspond to individual adsorber  vessel
cycles or system rotations that were at least 30 minutes in duration,  it
was not mandatory.  Because adsorption cycles  in different systems can
range from several minutes to several  hours, performance tests  based only
on 30-minute runs could  be biased  somewhat in  either direction.   The
proposed  performance testing provisions  would  have  resulted  in  adequate
                                   1-5

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determinations of the performance of these  systems, but the final
provisions provide for improved accuracy.
     The revised carbon adsorption system performance testing provisions
include separate requirements for systems with a single common exhaust
stack and for systems with individual stacks for each adsorber vessel.
The Agency believes that a common exhaust stack allows simpler performance
testing that is more representative of the  entire system's performance but
has included provisions for individual exhaust stacks because this  is
currently the more typical configuration.
     For adsorption systems with a common exhaust stack serving all the
adsorber vessels, the final performance testing provisions require  that
the system be tested as a whole.  Three test runs are required; each run
must correspond to one or more complete rotations through the sequential
adsorption cycles of all the adsorber vessels.
     For adsorption systems with individual exhaust stacks, the final
performance testing provisions require that each adsorber vessel  be tested
individually.  Three test runs are required for each vessel; each run must
correspond to one or more complete adsorption cycles.   A procedure has
been added to the compliance provisions for computing, a system efficiency
from the individual adsorber vessel efficiencies.
     The final performance testing provisions are likely to result in
somewhat increased testing costs in the case of a multiple-bed system
because each test run must include at least one cycle  for each bed.
However, this increased cost would be very small  relative to the  control
system cost and is reasonable considering the increased  accuracy  that will
result.
     The final adsorber monitoring provisions parallel  the final
performance testing provisions.   Again,  separate  provisions apply to
systems with a common exhaust stack and  those with  individual  stacks.   No
increase in monitoring costs is  anticipated.
     For adsorption systems with a common exhaust stack,  a monitoring
device must be installed on the  common exhaust stack and  one  also may  be
installed on the common inlet duct.   The owner or operator must report
each occurrence when the average emission level or  system  efficiency
(depending on whether the outlet only, or the inlet  and outlet gas  streams
                                    1-6

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 are monitored) over three successive system rotations varies  outside  the
 specified range.
      For adsorption systems with individual vessel exhaust  stacks,  a
 monitoring device must be installed on each individual exhaust  stack,  and
 a monitoring device also may be installed on the common inlet duct  or  on
 each individual inlet duct.  Each adsorber vessel must be monitored for  a
 minimum of one complete adsorption cycle per day.  A 3-day rolling  average
 emission level or efficiency for each vessel (depending on whether the
 outlet only, or the inlet and outlet gas streams are monitored) must be
 computed each day from the daily averages,  and these 3-day rolling
 averages must-be reported when they vary outside the specified ranges.
      Commenters supplied new data on the minimum relief valve size
 requirements and the cost for the proposed  standards requirement that all
 new solvent storage tanks be operated  at a  pressure of 103 kilopascals
 (15 pounds  per square inch gauge)  rather than  at atmospheric pressure.
 The EPA verified these data, conducted  a cost  analysis,  and  concluded  that
 no  cost-effective method existed  for controlling VOC  emissions from
 storage tanks  in this  industry.   The proposed  standard for solvent storage
 tanks  was withdrawn on November 25,  1986  (51 FR  42800). .
     Following  a' survey of all of the plants' in  the- industry,.  EPA'revised
 the 5-year  growth  projection from 21 new  lines to 5 new and  11 modified
 lines..  Of  these  16 affected lines,  1 new line and 4 modified  lines  will
 not have to  increase the  level of control because they are either  below
 the applicable  annual  solvent use cutoffs or above the baseline control
 cutoff  for modified  lines.   The changes in environmental, energy,  and
 economic impacts that  result from the revised growth projection are
 described in Section 1.2.
     The reporting  requirements of the magnetic tape NSPS also have been
 revised.  The regulation at proposal required semiannual  reporting of
months of noncompliance and of all 3-hour periods when monitor'values
exceeded the allowable variations.  The revised regulation  now requires
quarterly reporting of these events and  semiannual  reporting  of months  of
compliance and acceptable monitored values.   This semiannual  report would
include only a statement on the status  of the plant  and would contain no
data.
                                   1-7

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     Other  changes  include  the  addition  of Methods 18 and 25 as possible
methods to  determine  VOC  concentration and the  addition of monitoring and
reporting requirements  for  vapor  capture systems  that are not total
enclosures.  Minor  changes  have been made to  the  monitoring and reporting
provisions  for clarity  and  consistency with other VOC standards.
1.2  SUMMARY OF  IMPACTS OF  PROMULGATED ACTION
1.2.1  Alternatives to  Promulgated Action
     The regulatory alternatives  for new lines  are discussed in Chapter  6
of Volume I of the  background information document (BID)  for the  proposed
standards (EPA-450/3-85-029a).  These regulatory  alternatives  reflect the
different levels of emission control from which one was  selected  for  new
lines that  represents the BDT considering costs,  nonair  quality health and
•environmental impacts,  and  economic impacts for magnetic  tape
manufacturing facilities.   These  alternatives remain  the  same  for new
lines.
     For modified lines, cost analyses were performed for  specific
scenarios at specific plants.   These analyses included different  baseline
control levels than those evaluated for  new lines.  The baseline  control
levels evaluated for modified lines were  83 percent, 88 percent,  and
90 percent, all of  which were analyzed relative to 93 percent control, the
level of the proposed NSPS.
1.2.2  Environmental Impacts of Promulgated-Action
     The environmental  impacts  are discussed in Chapter 7 and Appendix E
of the Volume I (or proposal) BID.  Table 1-1 presents the environmental,
energy, and economic impacts.  The projected number of affected lines has
decreased from 21 new lines to 5 new lines and 11 modified lines.  One of
the new lines and two of the modified lines will be below the applicable
annual solvent use  cutoffs, and two of the modified lines will be above
the baseline control level cutoff; none of these lines would have to
increase the level  of VOC control;.  The required level of control  has been
lowered for all  modified mix equipment and some  modified coating opera-
tions.  Therefore,  all of the environmental, energy, and economic impacts
have changed as described in this  section and  in Section 1.2.3 below.
     The new and modified affected lines  will  be of several sizes.  Of the
projected 11 lines to be required  to  increase  their level  of control,
                                    1-8

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 1  new  and  3 modified  or reconstructed  lines are expected to be 0.33 meter
 (m)  (13  inches  [in.])  wide,  and  3  new  and 4 modified or reconstructed
 lines  are  expected to  be 0.66 m  (26  in.)  wide (the "typical" production
 size discussed  in this document).  The environmental and economic impacts
 are reported  as  the annual  impacts for typical  new and modified or
 reconstructed lines and as  the nationwide impact in the fifth year for all
 lines.   The impacts are reported assuming all  lines will be controlled by
 a  carbon absorber, which results in  the maximum estimate of impacts.
     The estimated fifth-year VOC  emission reduction achieved by the
 revised  NSPS  is  960 megagrams (Mg) (1,060 tons).   The estimated emission
 reduction  achieved by  a typical new  line  is  131 Mg (144 tons) or
 73 percent; that of a  typical  modified  or reconstructed line is 92 Mg
 (101 tons) or about 51 percent.  Nationwide  emissions will  be reduced by a
 total of about 60 percent in  the fifth  year  of  implementation.   The
 estimated  increase in  wastewater from  a typical  new coating line is 380 m3-
 (100,000 gal) (about 24 percent).  The  increase for a typical  modified or
 reconstructed line is  about 190 m3 (50,000 gal)  or 12 percent.   The
 nationwide increase in fifth-year wastewater generation is  expected to be
 2,40,0 m  (.625,000 gal),  about  17 percent.  The  estimated  increase  in  so.lid
 waste for a typical new coating line- is 120 kilograms  (kg)  (270  pounds
 [lb]) (17 percent).  A typical modified or reconstructed  Tine  is expected
 to increase solid waste  generation by about 10  percent  or 70  kg
 (150 Ib).  The estimated nationwide increase in solid waste  in  the  fifth
year is  800 kg (1,770  Ib).  This amounts to a 13 percent  increase.
     The secondary impacts of the revised NSPS on VOC in the wastewater
 and particulate matter,  sulfur oxide, and nitrogen oxide emissions  to  the
 atmosphere from  increased energy requirements will also be  lower than
 estimated for the proposed NSPS.   The estimated annual  increase  in
waterborne VOC from a typical new coating line is about 23 percent or
35 kg (80 Ib).  The estimated annual  increase irr waterborne VOC from a
typical modified or reconstructed line  is about 11 percent or 20 kg
 (40 Ib).   The estimated total  annual  increase in fifth-year waterborne VOC
levels  is 225 kg (500 lb) or 16 percent.  These estimates should be
considered as highly  tentative, however, since the actual increased levels
of VOC  in wastewaters will be determined by the permitting actions of
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 State and Federal regulatory officials charged with implementation  of  the
 Clean Water Act.  Accordingly, inclusion in this document of the  above
 estimated increases in future discharges of waterborne VOC does not
 constitute a legal determination that such discharges from point  sources
 will comply with applicable water quality or technology based effluent
 standards.  This judgment can only be made by the applicable local, State,
 or Federal regulatory officials on a case-by-case basis.
      The estimated annual increase in total secondary air pollutants from
 a typical  new coating line is 1.5 Mg (1.7 tons) (about 12 percent).  A
 typical  modified or reconstructed line is expected to increase these
 emissions  by about 0.7 Mg (0.8 ton)  (about  6 percent).  The estimated
 total  increase in secondary air pollutants  in the fifth  year is 9  Mg
 (10 tons)  (about 8 percent).
      Because the environmental  impacts have changed  from the Volume I BID,
 the Volume II  (or promulgation)  BID  becomes the final  Environmental  Impact
 Statement  for  the promulgated  standards.
 1.2.3  Energy,  Cost,  and  Economic Impacts of  the  Promulgated  Action
     The energy impacts of  the proposed standards  are  presented  in
 Chapter  7  of the Volume I BID.  For  the same reasons that the estimated
 environmental,  impacts  of  the revised  standards  decreased relative  to  the
 proposed standards, the estimated energy impacts also  decreased.-   The   '
 energy impacts  are presented in Table  1-1.  The estimated fifth-year
 impact is  about  8 terajoules (TJ) (7.8 billion British thermal units
 [Btu]) (9  percent).  The estimated annual energy impact of a typical new
 coating line is  about  1.3 TJ (1.3 billion Btu) (13 percent).  (The
 appearance in Table 1-1 that the incremental impact of a typical new
 coating line is  1.4 TJ is the result of "rounding error.)   The annual
 energy impact of a typical modified or reconstructed  line is expected to
 be about 0.6 TJ  (610 million Btu)  (6 percent).
     The cost impacts of the proposed standards are presented in Chapter 8
of the Volume I BID.  For the same reasons listed  above in  Section  1.2.2,
the estimated cost impacts of the  revised  standards are different than
those for the proposed standards.   The estimated impacts  are  presented in
Table 1-1.
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     It is now projected that four new coating  lines will  be constructed
and subject to the emission reduction provisions  of the  NSPS during  the
next 5 years.  Because the. value of the solvents  recovered by the  control
device will exceed the cost of operating the device, the annual  operating
cost of a typical new line after adjusting for  solvent recovery  will
result in a net savings (or credit) of about $73,000 per line.   With
respect to a typical modified or reconstructed  line, the annual  control
cost per line above the baseline is about $31,000.  This estimate  is  based
on contacts with industry and the model plant parameters and costs
developed prior to proposal.
     The nationwide annual cost of the NSPS at proposal  in  the fifth year
of implementation was a net credit of approximately $777,000.  Using  the
data presented above, the fifth-year annual cost of the  revised  NSPS  is
estimated to be a net credit of about $32,000.  This relative increase  in
the fifth year annual cost estimates is due to the decrease  in the number
of new lines for which net credits for solvent recovery  were obtainable
and the number of modified lines for which the required  additional control
costs exceeded the additional savings obtained from solvent  recovery.
     The'total capital control co'st-'of a typical new line .is about
$1.6 million.  That of a typical modified or reconstructed line  is about
$477,000.  These represent increases over baseline control  costs of
$32,000 and $477,000, respectively.
     The nationwide capital  control cost of the NSPS at proposal  in the
fifth year of implementation was approximately $455,000.   Using the data
presented above, the fifth-year capital  control  cost of the revised NSPS
is estimated to be about $3  million.   The percent increase  in fifth-year
capital cost of the revised  NSPS relative to baseline  is  about 52 percent.
     The economic impacts  of the proposed standards are presented in
Chapter 9 of the Volume  I  BID.  Those impacts  are based on  new magnetic
tape manufacturing lines and are unchanged  for the new  lines now  projected
in the first 5 years.  However,  as  discussed  above, it  is now expected
that a number of affected  facilities  in  the  coming years  will be  modified
or reconstructed lines.  An  analysis  of  modification scenarios submitted
by industry resulted  in  revised  economic  impacts but no change in the
conclusion that the economic impacts  are  negligible.  The maximum retail
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 price  increase under the modification scenarios  analyzed  is  projected to
 be  less than 0.5 percent.
 1.2.4  Other Considerations
     1.2.4.1  Irreversible and Irretrievable Commitment of Resources.
 Chapter 7 of the Volume I BID concluded that the  slight increase  in  energy
 use of the proposed standard was insignificant relative to the  total
 energy demand of the process equipment.  The increase in energy demand  of
 the revised standards is less than for the proposed standards,  so the
 impact on resources is negligible.
     1.2.4.2  Environmental and Energy Impacts of Delayed Standards.
 Chapter 7 of the Volume I BID concluded that there would be no  energy or
 environmental benefit to delaying the proposed standards because the VOC
 emission reduction far outweighed the slight increase in energy use.  This
 conclusion is still valid for the revised standards because the energy
 impact decreased more than the VOC emission reduction decreased.
     1.2.4.3  Urban and Community Impacts.   These standards will have a
 positive impact on urban areas and communities  because of  decreased VOC
 emissions.  However, the VOC  emission reduction achieved by the standards
 has decreased si nee,proposal.   There  should be  no decrease in employment
 in urban areas  and communities because the  revised economic analysis
 indicated that  the standards would have  little  impact  on retail  price or
profit.
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                       2.  SUMMARY OF PUBLIC COMMENTS

      A total  of 18 letters commenting on the proposed standards'and the
 BID  for the proposed standards were received.   Comments from the public
 hearing on  the proposed standards were recorded, and a transcript of the
 hearing was placed in the project docket.  A list of commenters, their
 affiliations,  and  the EPA document number assigned to their correspondence
 is given in Table  2-1..
      For the  purpose of orderly presentation,  the comments have been
 categorized under  the following topics:
      1.   Level  of  the Standard
      2.   Best  Demonstrated Technology (BDT)
      3.   Affected  Facility and Modification  and  Reconstruction,
 '  •  4.   Solvent Storage Tanks          '          • .        .     •  •.
      5.   Compliance  Provisions
      6.   Reporting and  Recordkeeping  Requirements
      7.   Cost  and  Economic Assumptions and Impacts
      8.   Suspension  of  the Standards
The comments,  the  issues  they  address, and EPA's responses .are  discussed
in the following sections  of this chapter.
2.1   LEVEL  OF THE STANDARD
2.1.1  Comment
     Two commenters  (IV-F-1 [Forbes], IV-D-5) said that EPA did not
properly consider the normal process variabi-lity associated with carbon
adsorbers in proposing a standard requiring 93 percent control of the
coating operation.   One commenter (IV-F-1 [Forbes]) reviewed the long-term
operating data for three carbon adsorbers presented in Tables C-6 and C-8
of the Volume I BID and concluded that the standard deviation for all
three systems exceeds 2 percent.  According to  this commenter, if the
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    TABLE 2-1.  LIST OF COMMENTERS ON PROPOSED STANDARDS OF PERFORMANCE
                 FOR MAGNETIC TAPE MANUFACTURING  INDUSTRY

Docket item No.a     Commenter/affillation


IV-D-1               K. C. Burton
                     Facilities Manager
                     General Products Division
                     IBM Corp.
                     Tucson, Arizona  85744

IV-D-2               E. I. du Pont de Nemours & Company, Inc.
                     Chemicals and Pigments Department
                     Technical Services Laboratory
                     Chestnut Run
                     Wilmington, Delaware  19898

IV-D-3               Mr. Robert Brothers
                     Director, Regulatory Affairs
                     Eastman Kodak Company
                     343 State Street
                     Rochester, New York  14650

IV-D-4               Mr. Gregory Fischer
                     Manager, Environment and Energy
                     Memorex Corp.
                    • San Tomas -at Central Expressway  -           •  -  •  •
                     Santa Clara, California  95052

IV-D-5               Mr. Arne "Carlson
                     Director of Loss Control and Environmental  Protection
                     Graham Magnetics Inc.
                     Subsidiary of Carlisle Corp.
                     U.S.  Highway 380
                     Graham, Texas  76046

IV-D-6               Mr. David W. Sorrelle
                     Senior Chemical  Engineering Specialist
                     Sony Magnetic Products Inc. of America
                     Highway 84 West.
                     Dothan, Alabama   36301

IV-D-8               Mr. Thomas W. 'Zosel
                     Senior Environmental  Specialist
                     3M Company
                     Post  Office Box  33331
                     St. Paul,  Minnesota   55133

                                                    ~~~~(continued)
                                   2-2

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                          TABLE 2-1.   (continued)
 Docket  item No.a     Commenter/affiliation
 IV-D-10              Mr.  Richard  H.  Forbes
                     Eastman  Kodak Company
                     Environmental Technical  Services
                     Health and Environment  Laboratories
                     343  State Street
                     Rochester, New  York  14650

 IV-0-13              Mr.  William  K.  Haynes
                     Environmental Coordinator
                     Ampex Corp.
                     Post Office  Box 190
                     Opelika, Alabama  36802

 IV-D-14              Mr. Thomas W. Zosel
                     Senior Environmental Specialist
                     3M Company
                     Post Office  Box 33331
                     St. Paul, Minnesota  55133

 IV-D-15              Mr. Arne Carlson
                     Director of  Loss Control and Environmental Protection
                     Graham Magnetics, Inc.
                     Subsidiary of Carlisle Corp.
                     U.S. Highway 380
                     Graham,  Texas  76046

 IV-D-17              Mr. Victor E. Sower
                     General  Manager
                     Tandy Magnetics
                     401 N.E.  38th Street
                     Fort Worth,  Texas  76106

IV-D-18              Mr. Thomas W. Zosel
                     Senior Environmental  Specialist
                     3M Company
                     Post Office  Box  33331
                     St. Paul, Minnesota   55133

IV-D-20              Mr. Gregory  Fischer
                     Manager,  Environment  and  Energy
                     Memorex Corp.
                     San Tomas at  Central  Expressway
                     Santa Clara,  California   95052

                                                    ~~~~(continued)
                                   2-3

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                          TABLE 2-1.  (continued)
Docket item No.a     Commenter/affiliation
IV-D-21
IV-D-28
IV-D-32
IV-E-61, 65, and
  82
IV-F-1
 Ms. Charlotte Hardaway
 General Products Division
 IBM Corp.
 Tucson, Arizona  85744

 Mr. Michael A. Brown
 Schmeltzer, Aptaker & Sheppard, P.C.
 Counselors at Law
 1800 Massachusetts Avenue, NW
 Washington, D.C.  20036-1879
 (Representing:
 International Tape/Disc Association
 10 Columbus tircle, Suite 2270
 New York, New York  10019)

 Mr. David R. Fritz
 Division Counsel
 Sony Corp. of America
 Sony Drive
 Park Ridge, New Jersey  07656            • .

 Mr. Arne Fladager
•Tandy Magnetic Media
 1600 Memorex1 Drive
 Santa Clara, California  9.5050

 Transcript of Public Hearing on Proposed  New Source
 Performance Standards for the Magnetic  Tape
 Manufacturing Industry.   Speakers  were:
                         Arne Carlson, Graham Magnetics,  Inc.
                         Gregory Fischer, Memorex Corp.
                         Richard H.  Forbes,  Eastman Kodak Company
                         William K.  Haynes,  Ampex Corp.
                         Victor E.  Sower, Tandy Magnetics
                         Glenn Ford, Tandy Magnetic Media
aThe docket number for this  project is  A-82-45.   Dockets  are  on  file  at
 EPA Headquarters in Washington,  D.C.,  and  at  the Office  of Air  Quality
 Planning and Standards in Durham,  North  Carolina.
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 long-term operational variability results  in a normal distribution of
 monthly measurements, two-thirds of all results would be expected to be
 within plus or minus one standard deviation from the mean, and 95.5 per-
 cent of all results would fall within plus or minus two standard
 deviations from the mean.  The commenter concluded that for a control
 system functioning at an average long-term efficiency of 95 percent and
 with a standard deviation of 2 percent, a point would be expected to fall
 below 91 percent about once every 4 years.  If so, a 100 percent efficient
 capture device ducting emissions to a control  device with a long-term
 average efficiency of 95 percent would be expected to fail  the "proposed
 standard of 93 percent control efficiency for  each and every month at
 least once and possibly twice every year.   The  two commenters recommended
 that the standard be established at 90 percent  for the coating operation
 in order to take process variability into  account.
      Response.  The commenter is correct in stating that the  standard
 deviations of  the monthly efficiency data  presented in Tables  C-6  and C-8
 of Volume I  BID exceed  2 percent.   The EPA undertook  additional  investiga-
 tion into the  circumstances  of the  reported efficiencies to determine if
 these variations  were  indeed  the result  of normal process variability.
      The  data  in. Table  C-6 are from  an IBM .Corporation facility. 'A repre-
 sentative of IBM  Corporation  indicated that the first  4  months of data
 listed  in Table C-6 (January  through April  1982) coincide with the startup
 phase of  both  the  carbon  adsorber and  the  process equipment it serves.1
 These months should, therefore,  be deleted  from consideration of the
 normal  variability  of the system.  The data from the remaining 8 months in
 1982  have  a mean efficiency of 98.7 percent with a standard deviation of
 0.53  percent.  Assuming a normal distribution of monthly measurements, the
 probability of  this carbon adsorber falling below an efficiency of 95 per-
 cent  due  to random  variability would be less than 10~9, i.e.,  one chance
 in a  billion.  These data show that with the use of BOT,  i.e.,  a total
 enclosure and a carbon adsorber, the standard of 93 percent  overall  reduc-
 tion  is achievable.
     Additional information also was sought on  the  two adsorbers  operated
by 3M Company (Table C-8).2  The specific data  received were declared
confidential by the company and cannot be discussed  here.  The  Agency's
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conclusion based on this  and  other  information  received  on  3M's  adsorbers
is that a standard deviation  computed from these  data  cannot  be  assumed  to
be representative of a  system that  has been designed,  maintained,  and
operated for consistent maximum performance.
     Information on this  subject also was sought  from  carbon  adsorber
manufacturers.  The representatives unanimously agreed that if properly
designed and operated,  fixed-bed carbon adsorption  systems can achieve
efficiencies of 95 percent or above at all times. ~    The operation of
such systems must be coordinated with production, and  adsorption/desorp-
tion cycles must be based on  monitored outlet concentration rather than
elapsed time.  Also, a  program of regular maintenance  must be established
and carried out.  Magnetic tape manufacturers adhering to these operation
and maintenance principles should have little difficulty'maintaining the
necessary adsorber efficiency.
     The Agency has carefully reviewed other control device data that
indicate some variability in  performance.  In 100 percent of the cases
studied, the excursions to performance levels below 95 percent could be
directly attributed either to  poor maintenance and system operation or to
an undersized 'control device.  The data from plants inside and outside the
magnetic type industry  derived from a period of normal  'operation indicate
that continuous long-term control  device efficiency in excess of  •
95 percent is achievable even with variations in operation.   Thus, based
on these data, which vendors  support, the Agency concludes that the stan- •
dard as proposed provides sufficient margin to account for the extremely
small variability expected of control devices.  (See also the response to
Comment 2.1.2.)
2.1.2  Comment.
     One commenter (IV-D-32)  made  the following public  comment about the
performance of carbon adsorption and the achievability  of the  proposed
standard:
     "The proposed rule's compliance provision is  based on a performance
     test whose duration, while unspecified,  is in terms  of  minutes and
     hours, not days and months,  the monitored parameter  data  reporting
     requirements are also written in terms  of 3-hour averages.   Because
     almost all of the Agency's record data  is based on monthly  averages
     there is nothing in the  record  addressing and resolving  issues
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      concerning the short-term variability of the control systems.  The
      93 percent overall recovery standard should be reduced to account for
      short-term variability."
      The commenter specifically questioned whether any supporting data
 exist for the Agency's position that 95 percent VOC removal efficiency can
 be achieved continuously by carbon adsorption systems over all averaging
 periods, including short-term periods.  The commenter submitted informa-
 tion which indicates 24-hour averages of efficiency of his adsorption
 system vary dramatically from day to day.   Highs above 95 percent were
 followed quickly by lows of less than 90 percent,  with no short-term
 pattern evident.   It was this information that caused the commenter to
 question the Agency's decision to require  corrective action by a source
 based on short-term evidence that the efficiency of the adsorber has
 failed to meet the required level of control.
 Response.
      Summary
      The EPA has reviewed the available  data on  the design,  operation,  and
 performance of carbon adsorption systems,  including data  submitted by
 commenters during the public comment period and  supplemental  information
 solicited by the Agency in  response  to this commenter1s concern,, and has
 concluded that carbon adsorbers  can  achieve a 95 percent  VOC removal
 efficiency continuously over the  short term as well as on  a  long-term
 basis  (these data are in  the project  docket).  Therefore,  the Agency has
 no reason to change  the standard  to  account for short-term variability.
     The  Agency acknowledges  that only relatively long-term carbon
 adsorber  efficiency  data  (2-week  to  1-month averages) were included in
 Appendix  C  of  the Volume  I  BID.  Since the time of proposal, EPA has
 evaluated  existing short-term performance data; collected additional
 design, operation, and  performance data from plants inside and outside the
 magnetic  tape  industry; and  reexamined, with the help of carbon
 manufacturers  and custom carbon adsorption equipment designers, the
 elements  that  could affect short-term adsorber efficiency.  This analysis
 has reinforced  the Agency's original  conclusion that a properly designed,
 operated, and maintained carbon adsorption  system can continuously
maintain a VOC  removal efficiency of  95 percent or  greater.  Although the
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commenter's  data were submitted after the close of the comment period, a
detailed  study  of the commenter's adsorption system was conducted.  It was
determined that this  carbon adsorber is  significantly underdesigned for
the  actual solvent loading  it is required to control.  This, results in the
system being operated a  significant portion of the time when the solvent-
laden air (SLA)  has already broken through one or more of the carbon
beds.  As a  result, this  system shows significantly reduced efficiency and
also significant variations in efficiency from day to day and cycle to
cycle.  There is no evidence to show that the poor performance of this
system stems from any inherent difficulty in adsorbing the particular-
solvent blend in use.  Therefore,,  the Agency has  concluded that those  data
are  not representative of a properly designed,  operated,  and maintained
system and that  the erratic performance  of the  commenter's adsorption
system can be traced  to these problems.   Additional  information on  carbon
adsorption generally  and on the commenter's  system can be found in  the
docket (IV-A-4).8
     However, review  of information  obtained  in response  to  the comment
has  led the  Agency  to revise the  averaging periods  for the testing  and
monitoring requirements from periods  of  a  fixed 'duration  to  periods that
include an integral number  of  complete adsorber cycles'.!   The  revised
periods remain short-term averaging  periods.   It  is believed  that these  •
revisions will result in more  accurate characterization of the  performance
of the carbon adsorption system.  The new requirements  are  included in the
promulgated  standard and are discussed in detail  in the summary of changes
in Chapter 1.
     Background
     The Agency's conclusion that carbon adsorbers can be designed and
operated to achieve recovery efficiencies in excess of 95 percent
continuously are summarized below.  The discussion is presented in three
parts:   theory,  design, and operation.
     1.   Theory.  The inherent phenomenon of adsorption makes it. highly
unlikely that the efficiency of ah adsorption system will  vary
significantly over a short time period.  Adsorption separation is based on
the molecular attractive (van der Waals)  forces between certain solids
(adsorbents)  and gases (adsorbates).  The molecules of adsorbate collect
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 on the surface of the adsorbent.  The capacity of the adsorbent for the
 adsorbate is largely a function of surface area but depends on other
 factors as well.
      Adsorption is an exothermic process.  The amount of heat liberated, a
 function of the magnitude of the attractive force, is equivalent to about
 two times the heat of condensation of the adsorbent.9
      Physical adsorption is a reversible process; the adsorbate can be
 removed from the adsorbent by heating (or by reducing pressure).   The
 affinity of an adsorbent for an adsorbate increases with decreasing
 temperature and decreases rapidly with increasing temperature,  making
 temperature change the most common means of removing adsorbates from the
 adsorbent.  The ease with which the adsorbate can be removed is a key
 element in sizing and operating an adsorption system.
    .  So-called "activated"  carbon is  the most commonly used  adsorbent  for
 removing low-concentration  organics from air  streams  because of their
 affinity for the adsorbent  and  the ease  of  desorption.   Carbon, typically
 made  from coal,  wood, petroleum pitch, fruit  pits, or coconuts, is
 "activated"  to increase  the surface to volume ratio by exposure to  steam
 or  carbon dioxide  at temperatures  in  excess of about 600°C (1100°F).
 These gases  attack the carbon and  increase the pore structure.  Surface
 areas  of typical  activated  carbons  range  from 600 to 1,600 m2/gram  (65 to
 180 acres  per pound).     Depending  on the precurser and particle size,
 this  amount  of  surface area could  be provided  by only the amount of carbon
 needed  to  fill 2 to  5 gal jars.  The variety  of precursers and options for
 activation permit  some optimization in the design of carbon for select
 organics.  The physical properties of the carbon (pellet size, pore size,
 and precurser) determine  the operating characteristics of the carbon, the
 adsorptive capacity  and rate, the resistance to gas flow, and the
 desorption characteristics.
     The capacity of a select mass of carbon to retain organics  is
 generally a  function of the amount and availability of surface area.  The
 size or diameter of the carbon pores and  the pore size  distribution  are,
 therefore, critical factors.  Large pore  sizes contribute little to
molecule capture; they serve mainly as passageways to  the smaller  pores
where the adsorption forces are  strongest.  Adsorption forces are
                                   2-9

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strongest in pores that are not more than approximately twice the  size of
the molecule to be adsorbed.    Most organic air pollutant molecules range
from 40 to 90 nanometers.  If the pores are less than 40.nanometers in
diameter, the organics will be unable to reach the internal surfaces.
     Adsorption may be considered a three-step phenomenon.  The organic
molecule first moves from the airstream to the external surface of the
carbon by diffusion.  Next, it migrates from the relatively small  external
surface area into the enormous pore surface area.  Finally, the molecule
adheres to a site within a pore.  The carbon is saturated when equilibrium
is reached (i.e., the number of molecules released by the carbon is equal
to the number of new arrivals).  At that time, the outlet organic
concentration will be in equilibrium with (equal to) the inlet
concentration.
     Because of the tremendous surface area available in activated carbon
and its affinity for gaseous organics, even at low concentrations, the
adsorption process is nearly instantaneous.  A very thin film of carbon
is, therefore, able to reduce the concentration in an airstream to near
zero until the carbon approaches saturation.
     Although in theory the adsorption phenomenon is totally reversible,
practical considerations, primarily the'cost of 'energy, prevent operators
from being able to heat the carbon to sufficient temperature to remove all
of the adsorbate.  Because of these practical  temperature limitations,
some organic molecules deep within the carbon  remain too tightly bound to
be removed.  This phenomenon is especially noticeable during the first few
adsorption cycles but continues incrementally  through the "life" of the
carbon.
    . The adsorbate (organics)  retained on the  carbon after a desorption
cycle is referred to as the "heel."  Because this heel  or residual
increases with successive cycles,  it gradually decreases the "working
capacity" of adsorbent—the ability to adsorb  new organics.   This  working
capacity decreases rapidly for the first  half-dozen adsorption cycles  of
virgin carbon, then only incrementally with additional  adsorption
cycles.  (At any point the carbon  can be  reactivated  completely  by
exposure to very high temperatures, at which time it  will  recover  its
original virgin carbon capacity.)
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      This subsequent gradual decrease in capacity is believed to be due
 primarily to buildup of high molecular weight compounds not released
 during the desorption cycle.  Other factors that contribute are oxidation
 of the carbon,  mechanical  plugging of the carbon pores, and fretting of
 the carbon.   Collectively, all  of the factors that detrimentally affect
 the carbon during its life are  referred to as "fouling."
      The  above-described unique inherent characteristics of activated
 carbon and its  affinity for organics are the key design features for an
 air pollution control device that differs little from solvent recovery
 systems that have been in  use by industry for decades.
      2.  Design of an Adsorption System.   Inasmuch as the  commenter's
 adsorber  is  a conventional "fixed bed"  system,, the following  discussion
 refers to the design of similar systems.   Fixed  bed  adsorption systems, by
 definition,  consist of two or more carbon beds that  are operated in
 sequence.   Each bed is operated as a batch  process,  and, in theory,  each
 bed  in a  system is  identical.   For this  discussion,  it  is  important  only
 to  understand how a single bed  functions  in  order  to  conclude  that a
 properly  designed and maintained  carbon  system can be operated at
 efficiencies  greater than  95  percent.
     •Jlt is well  recognized that the  affinity of  activated carbon for  •'•
 organics  is  so  great that  carbon will scrub, an airstream essentially free
 of organics  for a period of time.  As the carbon begins to saturate, it
 will begin to-allow organics'to escape from the bed in  the carrier gas.
 The designer  overcomes  this capacity constraint by increasing the amount
 of carbon through which the air must flow, thereby increasing total
 capacity  (although  specific capacity, the amount of adsorbate that a given
 mass of adsorbent can  retain, remains constant) and allowing the intervals
 between the times when  the carbon must be removed from service for
 desorption to be  extended.
     Figure 2-1  illustrates how quickly and dramatically carbon-removes
 organics from an  airstream.  It  shows the concentration profile of an
 airstream at some time, TU after a carbon adsorber bed is  placed on
 stream.  Figure 2-2  illustrates  the concentration profile at  a later  time,
T2, and Figure 2-3 presents the  concentration profile at a  still  later
time, T3.   Figure 2-4 represents the concentration  profile  at  a time,  T^,
after breakthrough has occurred.

                                   2-11

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              z  DIRECTION OF

              £   AIR FLOW
              UJ
              o
              o
                    INLET
                                BED DEPTH
                                     OUTLET
Figure  2-1.   VOC penetration of  activated carbon adsorption  bed  at time

                DIRECTION OF
              o
              UJ
              o

              I
                  AIR FLOW
              Ivt
                    INLET
                                BED DEPTH
                                     OUTLET
Figure 2-2.   VOC penetration of activated  carbon adsorption c-ed at  time
             z DIRECTION OF

             jS   AIRFLOW
                     I
             z
             UJ
             o
             z
>
en
<
O
                     I
                    INLET
OUTLET
                                BED DEPTH


Figure 2-3.  VOC  penetration of activated carbon  adsorption bed at time  T3


              •z.  DIRECTION OF  ^
^ AIRFLOW
<
Ex
z
UJ
0
z
0
o
o
o
> Y












i
i
^V 1
\ 1
\ 1 -
V
\i
V
1


i
| INLET BED DEPTH OUTLET
Figure 2-4.  VOC penetration of activated carbon adsorption bed at time
                                    2-12

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     If one envisions the  inlet concentration  as  a  "front"  which gradually
moves through the carbon bed,  two things become obvious.   First, the time
required for the front to  penetrate the bed can be  extended by increasing
the thickness or depth of  the  bed.  Second, at some time  shortly after T3,
when the front begins to emerge from the carbon bed (T^ in  Figure 2-4),
the outlet concentration will  climb rapidly until it reaches  equilibrium
with the inlet concentration.  The bed is then saturated, and no further
adsorption is possible.
     It is the operator's  responsibility to anticipate this predictable
cycle and ensure that the  bed  is removed from service before  the amount of
organic that escapes exceeds 5 percent of the total organic load
introduced during the adsorption cycle, the period  that the adsorber  is in
service.
     The operator, of course,  is interested primarily in the  outlet
concentration and how it varies with time.   Figure  2-5 presents  the outlet
concentration from a typical bed from the time it is placed in service
until the front begins to  break through,  causing the outlet concentration
to increase rapidly as the final layer of carbon at the outlet saturates
and equilibrium is achieved.
     If the operator properly anticipates the breakthrough time, he may
operate his'adsorber at exceedingly high  overall  efficiencies.  For
example, based on ,the range of values  found in this  industry, a typical
VOC inlet (X)  concentration might  be 3,000  parts  per million by volume
(ppmV)  and a typical outlet (Y) concentration  might  be  30  ppmV.12  The
result  is that the adsorber operates at 99  percent efficiency during the
bulk of its adsorption cycle.  Only after breakthrough  does  the
instantaneous  efficiency fall dramatically  enough  to influence the
efficiency of  the entire cycle.
     Figures 2-1  through 2-4 represent  the  instantaneous performance of a
carbon  bed at  specific times during  a  single adsorption cycle.  As stated
above,  Figure  2-5 represents the outlet concentration curve  from the same
bed over the same period of time.   None of  the  figures demonstrate the
effect  of fouling,  which is appropriate because fouling does not  affect
instantaneous  performance or outlet concentration.   Rather,  the effect of
fouling is measured  in terms of the  length of each adsorption  cycle.
                                   2-13

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cc
III
o
i
o
te

§  y
                   TIME
'breakthrough   TSaturation
       Figure-2-5.  Typical  carbon adsorption breakthrough  curve.
                                   2-14

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 Fouling  is generally a  long-term  phenomenon  and,  for many adsorption
 systems,  has  little appreciable effect  on  the  performance of an adsorber
 over  a period of years.  The commenter's organics,  however,  include some
 that  are  not easily desorbed and  may  have  second-order  effects that hasten
 fouling.  Because of fouling, the useful life  of  the commenter's carbon is
 measured  in months rather than years.   Its effect on operation manifests
 itself by reducing the  time before breakthrough occurs  on a  bed.
      As explained earlier, fouling decreases the  active sites  within the
 carbon bed available for adsorbing organics.   The result  is  a  more  rapid
 decrease  in working capacity than would be encountered  with  many organic-
 bearing airstreams.  Since the inlet organic load to  an adsorber is
 presumed  constant, the  reduced working capacity causes  the adsorber  to
 approach  breakthrough with increasing rapidity.   If  the operator does not
 coincidentally reduce the time the adsorber remains  in  service,  then  he
 greatly increases the amount of organic allowed to pass through  the  system
 (as illustrated in Figure 2-4) as  the bed operates in a post-breakthrough.
 period.
      Information submitted by the  commenter in response to our
 investigation revealed precisely  this flaw in operation. . The commenter  '
 routinely permits beds to.-remain  in' service not only beyond breakthrough
 but well  into ,and beyond saturation as shown in Figure 2-5.13  This has  a
 dramatic effect on cycle efficiency.   If breakthrough is achieved in'
 2 hours and an adsorber is allowed to operate 4 hours, the average cycle
 efficiency would decrease from 99 percent immediately prior to
 breakthrough to about 50 percent 2 hours later.
     Given this overwhelming effect on efficiency  of operation beyond
 breakthrough, why would an operator not remove  a bed from service before
 breakthrough occurs?  There are  several  possible reasons.
     1.  The operator may not be aware of how quickly the concentration
 rises after breakthrough and the resulting  deleterious effect on the
 efficiency of his adsorption system.
     2.  The operator may have no  way  of knowing when breakthrough occurs
 (suitable analytical  instruments  have  not been  installed).
     3.  The operator may not have a replacement bed  properly desorbed and
cooled, ready for service.
                                   2-15

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      The first two reasons are operational  problems and easily overcome.
 The third may be a consequence of the original system design and not
 easily overcome without significant cost.   For example, assume an operator
 purchases a two-bed system where he plans  for one to be in service
 (adsorbing) while the second is desorbing.   Further, assume the system is
 designed for a 3-hour adsorption cycle,  a  1-hour heating cycle, and
 0.5 hour to cool  the regenerated bed to  prepare it for service.  With this
 design,  the operator will  have little problem during the early life of the
 carbon.   It is only as the normal  decrease  in working capacity begins to
 limit the adsorption cycle to  about 2 hours  onstream that the operator may
 be  forced to compromise.
      Good operating practice would  cause him to replace the carbon  before
 the adsorption cycle is equal  to the combined times  required for  steaming
 and cooling.   If  he does not replace the carbon,  however,  he is forced to
 compromise either by leaving one bed on stream too long with the  attendant
 losses after breakthrough  or by placing in service a bed that has not  been
 properly regenerated.  The latter action would reduce  overall  efficiency
 because  of the reduction in  adsorptivity and,  subsequently,, the
 equilibrium capacity and'the working capacity.  Premature  breakthrough
 would be inevitable  and instead  of  exhausting  at  concentration  Y  (see
 Figure 2-1),  the  outlet concentration could  be  significantly  higher.
      3.   Operation.  After completing- this review  of carbon  adsorption
 theory and  practical design  of carbon adsorption  systems in  response to
 public comments,  the Agency  continues to believe that a  sudden  change  in
 the efficiency with which an adsorber removes organics from an  airstream
 an  indication  that the system is improperly designed, maintained,  or
 operated.  The following discussion of factors that can affect  performance
 should reinforce the conclusion that, if performance factors are properly
 considered during the design stage, only improper operation could  cause
 subsequently unpredictable performance.
     The major factors affecting performance  are temperature, humidity,
VOC concentration, volumetric flow rate,  "channelling" (nonuniform flow
through the carbon bed), regeneration practices, and changes in the
relative concentrations of the  VOC's admitted to the adsorption system.
The potential effects of these  factors and  countermeasures are discussed
below.

                                   2-16

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      Temperature.   As  temperature rises, the capacity of the carbon to
 adsorb  VOC's  rapidly diminishes.   For instance,  a rise in temperature from
 25°  to  60°C (77° to 140°F)  will reduce the equilibrium adsorptive capacity
 of one  type of  carbon  for toluene (at a concentration of 2,500 ppmV) by
 approximately 25 percent, from a  specific mass ratio of about 4 (0.37 kg
 toluene per kg  carbon  [Ib toluene per Ib carbon])  to about 3 (0.29 kg/kg).11*
 This would  decrease the working capacity of the  carbon bed and the useful
 adsorption  time, making an  adsorption system operated by a time cycle
 vulnerable  to an apparent rapid decrease in efficiency.   The potential
 causes  of elevated  temperature can be avoided by ensuring that the design
 properly compensates for the range of conditions that might be encountered
 during  operation.   These conditions  include the  temperature of the inlet
 SLA  stream, the ambient conditions surrounding the adsorber,  and
 sufficient  time to  cool each carbon  bed  thoroughly before it  must  be
 returned to service.   Once  the system is  installed,  the  last  parameter  is
 the  only one .over which the operator  can  exercise control.  The operator
 must recognize the  point at which  declining working  capacity  prohibits
 proper  cooling of the  bed and threatens the efficiency of the  system.
      The bulk of the VOC in the SLA  stream  at a magnetic  tape  coating
•pi-ant will originate in the drying dven(s).  The hot  exhaust "gases must  be
 cooled  to the'design operating temperature of the adsorber  (e.g.,  from
 80°C [180°F]  at the oven outlet to 40°C  [100°F]  or less at the adsorber
 inlet).  Care must  be  taken to ensure that the cooler is  designed  for the
 worst-case SLA stream  (i.e., the greatest heat load combination of
 volumetric flow rate,  oven exhaust temperature,  and sensible heat content
 of SLA  stream).
     Adsorber performance also can be affected by external temperatures.
 Care,should be taken to ensure that equipment is  protected from
 surrounding heat sources such as  steam turbines or direct sun that might
 increase the typical operating temperature of 40°C (100°F) above the
 design value.
     Humidity.  Humidity is  not  expected to be a  problem in the magnetic
 tape industry because  product quality concerns cause  most plants to
 condition the air to the application/flashoff areas and drying ovens.
 Further, inasmuch as the carbon  is normally saturated after the steaming
                                   2-17

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 and  cooling  desorption  cycle,  humidity is rarely a concern in any
 adsorption system.   In  an  extreme situtation,  humidity can decrease
 working  capacity, although the effect is  significant only when the
 relative humidity is  high  or the  VOC  concentration is low.  Even then,
 carbon may still be  a viable control  option, although pretreatment with a
 condenser or other device  to remove water vapor  may be required,
 particularly for low-organic concentration streams (<300 ppmV).
     VOC Concentration.  The working  capacity  of carbon increases as VOC
 concentration increases.   For  instance, the specific mass capacity of one
 type of  carbon for toluene at  25°C (77°F)  increases by about  5 percent
 when the concentration  rises from 2,000 to 3,000 ppmV.llf  Since  the outlet
 concentration from the  adsorber is not significantly affected  by the inlet
 VOC  concentration, the  instantanepus  efficiency  of a carbon adsorber will
 increase almost imperceptably  from 98.5 to 99.   The increased  mass  loading
 rate, however, will shorten  the effective  adsorption cycle since the
 working  capacity will be consumed approximately  70 percent more  rapidly
 causing  quicker breakthrough.  Therefore,  the  adsorption system  must be
 designed with adsorption,  desorption, and  cooling  cycles to accommodate
 the  highest  inlet concentration to be expected from  the  system.
     Low  inlet concentrations  can also affect  efficiency.  Since  the
 outlet concentration from  an adsorber is determined  by the saturation
 condition of  the last few  inches of carbon and is  relatively constant,  a
 significant decrease in inlet  concentration can affect overall
 efficiency.   For instance, if  the inlet concentration of a system with  an
 outlet concentration of 30 ppmV were  to fall to 500 ppmV for an entire
 cycle, the adsorber's efficiency during that cycle would be only
 94 percent.  This could occur  in an adsorber system that normally serves
 four coating operations and operates  with  an inlet concentration of
 2,000 ppmV if three  coaters were to shutdown,  and the operator allowed the
 other exhausts to feed the adsorber.   The  three offstream exhausts would
 dilute the VOC concentration from the  fourth line.  Such a decline in
 adsorber efficiency  can be avoided by  adjusting the airflow volume to
maintain a constant  inlet concentration.   Obviously, the minimum  expected
 inlet concentration  must be a consideration in  the design of  an adsorption
system.
                                   2-18

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      Volumetric Flow Rate.  The efficiency of a carbon adsorber is
 unaffected by reductions in the volumetric flow directed to it (the only
 tangible effect is that the adsorption cycle can be extended because the
 available working capacity will be filled at a slower rate.  It is
 difficult to conceive how the flow through an adsorber can increase
 significantly above the design rate during normal  operation.  One possible
 way is if operator error causes removal  of one bed from adsorption service
 in a system that normally operates with  two or more beds on line.   This
 could have an adverse impact on efficiency if the  resulting increase in
 velocity through the bed reduces the contact time  between carbon  and the
 SLA below some critical  minimum necessary for adsorption to take  place.
      Channelling.   Channelling means that the flow through  the  carbon  bed
 is not uniform;  poor flow distribution due to original  design  is  the most
              g
 common cause.    When channelling occurs,  the inlet gas  stream  follows  a
 narrow path  through  the  carbon,  and,  therefore,  the portion of  the carbon
 that contacts  the  SLA is  reduced.   The working  capacity of  the  carbon  that
 is exposed will  quickly  be  consumed,  and  breakthrough will  occur
 prematurely.
      Regeneration  Practices.   Failure to  regenerate  the carbon  bed  to
 design  conditions  during.the desorption cycle can  cause variations, in
 adsorber  efficiency.   In  all adsorption systems, some residual  VOC's (the
 heel) will be  left on  the carbon bed after the desorption cycle because
 the  energy cost  that would be  incurred to desorb the most tightly held
 molecules deep in the  carbon pores  is prohibitive.   The adsorption system
 is designed to accommodate the heel and still achieve a specified level of
 performance.   If the desorption cycle is inadequate and VOC's in excess of
 the  design heel  remain on the carbon when the adsorption cycle is begun,
 the working capacity of the carbon bed will be reduced,  and breakthrough
will occur sooner.
     Good design will ensure that desorption steam  and cooling air are
 introduced countercurrent to the direction of the SLA stream flow.   The
outlet concentration that prevails prior  to breakthrough is  primarily
determined by the condition of the carbon at the exit of the carbon bed
and will vary little with variations in other parameters.   Countercurrent
desorption and cooling will  ensure that the last few inches  of  the  bed
                                   2-19

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 (during the adsorption cycle) are  the  cleanest  and  coolest carbon in the
 bed.  The quantity and quality of  steam  applied to  the  carbon bed during
 regeneration must be sufficient  to return  this  portion  of  the carbon bed
 to design conditions.  Also, it  is important  that the steam be uniformly
 distributed across the carbon bed  so all the  carbon in  the last few inches
 of the bed will be regenerated equally.  If the problem of poor steam
 distribution is very pronounced, some  portions  of the bed  may be
 regenerated poorly or not at all throughout the depth of the bed.   When
 the adsorber vessel is brought back into service, these parts of the bed
 will experience breakthrough quickly,  the  outlet concentration of  the
 system will quickly rise above the design  level, and adsorber efficiency
 will be reduced correspondingly.
     VOC Characteristics.  The adsorptive  capacity  of carbon varies  with
 the compound to be adsorbed.  Generally, compounds  with  low  vapor
 pressures will be adsorbed preferentially  over  those with  high vapor
 pressures, and nonpolar compounds  will displace polar ones.   The capacity
 of the carbon varies somewhat from compound to  compound, and  each  compound
 or mixture of compounds will have  its own  unique working capacity.   Thus,
 the length of adsorption service prior to  breakthrough will  be fixed  by
 the composition of the SLA stream.  Variations  in working capacity 'will
 not adversely affect efficiency if a breakthrough monitor is  in use  and
 the adsorption system is designed  with adequate capacity for  the least-
 adsorbable formulation to be used  at the facility.   Proper system design
 will allow sufficient cycle time to ensure that a regenerated  adsorber.
 vessel will be ready to receive the SLA stream when the monitor indicates
 that breakthrough has been reached.
     The presence of ketones in the SLA stream also can affect adsorber
 performance.  See Comment 2.7.1 for a discussion of these effects.
 Conclusions
     All of the performance factors that affect the reduction efficiency
 of a carbon adsorber are controllable if the  system has  been properly
 designed to handle the organic  material actually delivered  to  it.
 Furthermore, monitoring of the  outlet concentration  from each bed is
technically feasible and commonly practiced and  provides a  means of
discerning the appropriate time  to  remove a bed  from adsorption service
                                   2-20

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 regardless  of  the working capacity of the carbon.15  The functional
 difference  between fresh  virgin carbon and carbon that is near the end of
 its  useful  life  is the length of time the carbon can remain onstream
 before  breakthrough occurs,   the air pollution control efficiency is
 primarily a function of how  long the carbon bed is allowed to remain
 onstream past  breakthrough,  not the age of the carbon.
      The age of  the carbon affects only the working capacity, hence, the
 length  of time that it can remain onstream in  an adsorptive capacity
 before  breakthrough occurs.   In order to maintain a high  removal
 efficiency,  an operator will  have to replace his carbon when the
 adsorption  cycle  becomes  too  short to permit the offstream bed  to be
 properly desorbed  and  cooled.   The operator may choose to replace the
 carbon  if the  incremental  steam costs that  result from the increased
 frequency of desorption make  it more economical  to replace the  carbon.
 2.1.3   Comment
     Three  commenters  (IV-D-3,  IV-F-1  [Haynes],  IV-D-13,  IV-D-32)  noted
 that, the standard  for  the  pressure  sensitive tapes  and  labels (PSTL)
 industry, which includes the plant, that  the Agency  is  relying on  for
 technology transfer, was set at  only 90  percent  control.   One commenter
 (IV-D-3) indicated  that the standard  for the magnetic tape .industry
 should, therefore,  be  no higher.  Another commenter  (IV-F-1 •[Haynes],
 IV-D-13) believes that  the standard  should be less than 90 percent.  The
 third commenter stated  that EPA must justify the  imposition of a stricter
 standard on the magnetic tape manufacturing industry.
     Response.   The PSTL data were used'in the  development of the magnetic
 tape manufacturing  industry standard because these two industries are
 similar both in the processes used and in the controls determined to be
 BDT.   However,  different levels of control are  appropriate for the two
 industries.   Some products manufactured at PSTL plants retain sufficient
 solvent in  the  dried web such that 93 percent control of applied solvent
was judged  not  to be achievable in all cases.  There is virtually no sol-
vent  retained in  magnetic  tape products after they leave the drying ovens;
thus, all  the applied solvent is available for  capture by  a well-designed
capture device.  If, however,  an owner or operator submits specific
information  to  the Administrator that justifies  the need for retained
                                   2-21

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 solvent  in  a product, the revised  standards  now allow  the  fraction of
 retained  solvent to be  included  in the  material  balance  calculation of VOC
 recovered.  In  addition, the  level of the  proposed  NSPS  for  coating
 operations  at magnetic  tape plants was  not based solely  on the  data from
 the one  PSTL plant.  A  test of a magnetic  tape  line with control  of only
 oven emissions  demonstrated 93 percent  control  of applied  solvent.   A
 representative  from a second  plant controlling  only oven emissions  has
 stated that a 92 percent overall reduction in applied  solvent is  achieved
 by the control  system.  Use of a well-designed  capture device in  the
 application/flashoff area would  be expected  to  increase the  control
 efficiency.  Therefore, the Agency concludes that the proposed  requirement
 for 93 percent  control  of VOC emissions from new coating operations  is
 supported by the available data.   (See Section 2.3  for further  discussion
 of the level of control on new and modified coating operations.)
 2.1.4  Comment
     One commenter (IV-F-1 [Haynes], IV-D-13) stated that the baseline
 level of control presented in the BID (83  percent)  is too high.  According
 to the commenter, the State implementation plan  (SIP) level of  control at
 his facility is 53 percent, and the proposed increase in the required
 level of controT ta 93' percent is unreasonably large.
     Response.  The baseline control  level  of 83" percent was based on
 existing State regulations.  Emissions from coating operations  in the
 majority of the States  (including the commenter1s State)  are limited to
 0.35 kg of VOC emitted per liter (a)  of coating applied (2.9 Ib.of VOC
 emitted per gal of coating applied).   A typical  coating composition in
 this industry is 0.72 kg of VOC per a of coating (6 Ib  of VOC per gal of
 coating), and the average solvent density is  0.90 kg per  a  (7.5  Ib per
 gal).
     The calculations were performed  assuming that the  coating line must
 emit no more VOC than would be emitted  if the line used a low-solvent
 coating (0.35 kg VOC/a coating minus  water  [2.9  Ib VOC/gal  coating minus
water)) equivalent to the State emission regulation. The baseline control
 level was calculated  on  the basis of  the volume  of coating  solids  applied
 as follows.
                                   2-22

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 Typical coating composition by volume:

        0.72  kg  VOC/a,  coating   n  Qn n  unr/     . .   •  .
          0.90 kg  VOC/j,  VOC    =      a  voc/a coating minus water
                                (0.8 gal  VOC/gal  coating minus water)
      Thus,  the  typical  coating is 80 percent VOC by volume and 20 percent
      solids  by  volume.

 Typical coating composition—mass VOC  per volume coating solids:

     0.72 kg VOC/a coating     , .  .  ..._ .
    0.20  a solids/a coating  =  3'6  k9 VOC/a  So1lds  (30 lb  VOC/gal  solids)

 Low-solvent  coating  (equivalent to State  regulations) composition by
 volume:

   'o.909kgQVOC/a°VOCnq = °*39 * VOC/£ C°at1ng (0.39 gal  VQC/gal  coating)

     Thus, the  compliance low-solvent coating  is 39  percent VOC  by volume
     and  61 percent solids by  volume.

 Low-solvent coating composition—mass VOC per volume coating  solids:

   0.61 i solids/abating = °'6 ^ voc/!l S0l1ds  (4-8 lb VOC/gal  solids)

 Emission reduction achieved by the State regulations:

      3.6 kg VOC/t solids-0.6 kg VOC/a  solids _ n 0_
               3.6 kg VOC/s, solids            ~ °-83
              j
     Thus, the control level  achieved by  the State  regulations is
83 percent.   Because  the majority  of the  States require  the same  VOC  con-
trol  level,  the  Agency believes that this  is a reasonable baseline level.
Furthermore,  the Agency's analysis has  shown that the level  of the stan-
dard,  93 percent,  is  achievable and reasonable relative  to this baseline.
                                   2-23

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2.1.5  Comment
     Two commenters stated that the capture efficiency of a
negative-pressure enclosure would be less than estimated by EPA because of
the need for periodic operator access (IV-F-1 [Sower], IV-D-5).  This
problem would be compounded in the case of rapidly evaporating solvents,
thus further reducing the control efficiency of the enclosure.  The com-
menters stated that any reduction in capture efficiency below 98 percent,
assuming a 95 percent control device efficiency, would render attainment
of overall 93 percent emission control impossible.  One of the commenters
(IV-D-5) stated that because the type of coating used in the PSTL test .
would have lower emissions in the flashoff area than magnetic tape
coatings, fugitive VOC emissions would be lower, and, therefore, the level
of control could be higher than in the magnetic tape industry.
     Response.  While it is true that periodic operator access is
necessary in.web coating operations, this fact does not preclude achieve-
ment of the standard.  Industry representatives (including.these
commenters) agreed at a meeting with EPA held on May 7, 1986, that the
standard is technologically achievable.    The PSTL plant cited above
achieved a 93 percent reduction despite the relative difficulty of con-
trolling an operation, characterized by short production runs employing.a
wide variety of solvents and solvent blends.  Also, as was discussed in
the response to Comment 2.1.2, one magnetic tape plant controlling only
the oven achieved 93 percent efficiency.
     The Agency does not agree that coatings used in the magnetic tape
industry will suffer proportionally greater fugitive losses  in the appli-
cation/flashoff area than will those used at the PSTL plant  because of the
relatively low line speed at the PSTL plant and the use of coatings of
similar solvent content.  In any case, emissions within a properly
designed and operated enclosure will be directed to the control  device
just as are those within the oven.
2.1.6  Comment
     One commenter (IV-D-28) stated that EPA should consider the extent to
which the control level set by the NSPS is achievable by existing industry
participants.  The commenter stated that some companies do not currently
possess the required technology, while others already have it and consider
                                   2-24

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  It  to  be proprietary.   The  commenter believed that the regulation could
  threaten the  existence  of a company that does not already possess
  technology  that  is  not  available to it.
      Response.   The NSPS program encourages  the development of more
  efficient capture and control  technologies.   New source performance
  standards are based on  BOT  that  yields the greatest emission reduction
  without  imposing unreasonable  impacts.   The  control  device technology
  necessary to meet these standards  is  openly  available  to the entire
  industry.   Furthermore, applicable  industrial  ventilation technology  that
  will allow  the standards to  be met  is generally  available to all  members
  of  this  industry.   For those sources choosing  to  demonstrate compliance
  using  the equipment  alternative  method,  there  is  sufficient  leeway  allowed
  in  the structure of  the total enclosure  to permit development  and use  by
  all segments of the  industry.
  2.2  BEST DEMONSTRATED TECHNOLOGY (BDT)
  2.2.1  Coating Operation
      2.2.1.1  Comment.  Several commenters stated that magnetic tape
 products, particularly computer tape, cannot be produced  in the sort of
, negative-pressure total  enclosure required by the proposed standard for
 the coating operation (IV-F-1 [Carlson,  Forbes], IV-D-3,  IV-D-4,  '        '.
  IV-D-6).   The commenters described a "clean room operation" as standard
 operating practice  in the  production of high-quality computer and video
 tapes and stated  that the  trend is toward more stringent standards for
 "clean  room" environments.   In  a  "clean  room," air is filtered so that it
 contains  less  than  100 particles  0.15 to  0.5  micrometers in size or  larger
 per cubic foot of air.   This prevents dust and debris in normal room air'
 from settling  on  the wet tape and causing a quality  defect that would  lead
 to rejection of the  product  (IV-F-1  [Carlson]).   Because the  "clean  room"
 must be maintained at positive,  pressure,  VOC  emissions  will  be greater
 than they would be in a  negative-pressure enclosure.  One commenter
 (IV-F-1 [Forbes]) stated that neither  the Volume  I BID  nor the  proposal
 preamble  adequately  addresses the quality issue and  that  there  is  no
 information  in the Volume I  BID about the actual use  of  negative-pressure
 enclosures at magnetic tape  plants.
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     Response.  A meeting of EPA and industry representatives was held on
May 7, 1986, to discuss industry concerns with the proposed NSPS.
Attendees from industry included all those who presented comments at the
public hearing (IV-F-1) except Mr. Richard H. Forbes of Eastman Kodak
Company.  Mr. Mark Damas of CBS, who did not present comments at the
public hearing, also attended the meeting in May.  At the meeting,
industry representatives agreed that all types of magnetic tapes can be
manufactured at facilities equipped with BDT.  The concern expressed by
industry v/as the cost to achieve the standard at modified and recon-
structed facilities (see Section 2.6), not the achievement of 93 percent
control or problems with product quality.  The air handling techniques
designated as BDT are currently in use in the magnetic tape industry,
including at least two plants manufacturing computer tape.  On this basis,
the Agency concludes that BDT is practical and that the standard is tech-
nologically achievable for all segments of this industry.  See the
response to Comment 2.2.1.2 for further discussion of the considerations
appropriate to the determination of BDT.
     2.2.1.2  Comment.  Because of the concerns for product quality
discussed in Comment 2.2.1.1, some commenters (IV-D-32, IV-F-1 [Carlson,
Forbes]) said that BDT has not been'demonstrated for the magnetic tape"
industry and that extensive development costs would be required by the.
industry to meet the proposed standard.  One commenter (IV-F-1 [Carlson])
said that the standards should betrewritten "using a BDT from the magnetic.
tape industry" (i.e., control of the oven only)  and that "different BDT's
might be needed for each segment" of the industry.  The other commenters
(IV-0-32, IV-F-1 [Forbes]) said that the PSTL plant that provided the data
supporting the proposed standard would not be capable of producing high-
quality magnetic tape and would, therefore,  not be considered an adequate
demonstration of BDT for the magnetic tape industry.   One commenter
(IV-F-1 [Carlson]) said that, according to his review of previous court
cases, technology transfer should be based on specific equipment rather
than a process.
     Response.  The commenter (IV-F-1 [Carlson])  was  contacted for
additional information about the court cases to  which he referred in his
comments.  He was unable to supply specific  citations.   The Agency has
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 located several decisions that deal in part with  the  appropriate
 considerations in the determination of BDT.   In no  case was  the  issue
 raised concerning a distinction between processes and  specific pieces of
 equipment.
      In the case of International Harvester v. EPA. 478 F.2d 615
 (D.C. Cir. 1973), the Court ruled that a projection based on existing
 technology may be made, subject to the restraints of reasonableness.   This
 stance was reiterated by the Court in the cases of Portland Cement
 Association v. Ruckelshaus. 486 F.2d 375 (D.C. Cir.  1973), Essex Chemical
 Corp. v.  Ruckelshaus. 486 F.2d 427 (D.C.  Cir.  1973), and National Asphalt
 Pavement  Association v. Train. 539 F.2d 775 (D.C.  Cir. 1976).  This
 concept was upheld in the case of Sierra Club  v.  Costle. No.  79-1565  (D.C.
 Cir.  1981), in which the Court stated  ".  .  .we believe EPA does  have the
 authority to hold the industry to a standard of improved design and opera-
 tional  advances,  so  long as there.is substantial evidence  that  such
 improvements are  feasible and  wtll produce  the improved performance neces-
 sary  to meet the  standard."   In CPC International, Inc. v.  Train.
 515 F.2d.  1032 (D.C.  Cir.  1972), treating  the analogous  section  of  the
 Federal Water Pollution Act  (Section 3.06(a)(l);), the Court  stated:     •  •
      (t)o  base its standards on transfer  technology, the EPA
      must:   (1) determine that  the transfer technology
      ...  is  available  outside the  industry;  (2) determine
      that  the  technology  is transferable to the industry; and
      (3) make  a reasonable prediction that the technology
      ...  will be capable of removing the increment required
      by the new source standards.
Thus, the courts have indicated that the overriding concern is that the
Administrator  arrive at an achievable standard  through  a reasonable deter-
mination of BDT.
     The NSPS  for the magnetic tape manufacturing industry is an
achievable  standard based on a reasonably determined  BDT.  The control
technology designated as BDT has been demonstrated  at a PSTL plant to
achieve the percent reduction required by this  standard.  These  air
handling and control  technologies  are currently in  use  in the  magnetic
tape industry, including the computer tape sector where product  quality is
critical.   The equipment, solvents, and  processes used  in these  two web
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coating industries are similar and would be expected to produce  similar
SLA streams.  A technological system that can control the  SLA  streams  of
the PSTL industry to the required degree can be reasonably expected to do
the same in the magnetic tape industry.  Thus, the Agency  has  made a
reasonable determination of BDT and has formulated an achievable  standard,
satisfying the requirements mandated by the courts.  (See  related
discussion of the level of the standard in Section 2.1 and the issue of
product quality in Comment 2.2.1.1.)
2.2.2  Mix Room
     2.2.2.1  Comment.  Two commenters (IV-F-1 [Fischer],  IV-D-3)
addressed the selection of carbon adsorption as BDT for mix room emis-
sions.  According to one commenter (IV-F-1 [Fischer]), the cost to install
control equipment is not justified, particularly for an existing facility,
because only 3 percent of plant-wide emissions are from the mix room.  The
commenter recommended that BDT for mix equipment be redefined  as tight
covers.  A second commenter (IV-D-3) said that control costs for a
separate carbon adsorber are significantly underestimated  in the BID and
result in unrealistic cost-effectiveness' values.  The commenter also
stated that even where a common carbon adsorber could be used, the.incre-
mental cost of nearly '$1,000 per ton is unreasonable compared  to other
standards that have been promulgated.
     Response.  The Agency's cost analysis presented in the Volume I BID
demonstrated that the cost to control  mix room emissions with  an add-on
control device was reasonable only if  the same control  device  could be
used to control coating operation emissions and mix room emissions.  The
results of this analysis agree with the commenter1s statement  that
separate control of mix room emissions with an add-on control   device is
not cost effective.  The standard for  the mix room and  the proposed
affected facility definition presented at proposal  were selected  so that
carbon adsorption control of mix room  emissions would occur only  when
there was also an affected coating operation,  and,  thus,  emissions from
the two sources could be controlled by the same control  device.  At that
time, growth in the industry was projected to be as a result of construc-
tion of new lines.  Thus, new or existing mix equipment would  become
subject to the NSPS when a new coating operation and  its  control  devices
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 were being constructed and capacity for the mix  equipment  could  be
 included in the control device design.
      Since proposal, EPA has accepted the  industry's allegation  that
 growth in the industry will occur primarily from modification or
 reconstruction of existing lines rather than construction  of new lines
 (see Comment 2.3.4).  In this situation, existing mix equipment  may be
 modified when there is no construction of a new control device and the
 existing control device may not have sufficient extra capacity to
 incorporate mix room emissions.  Two modification scenarios were provided
 by industry after the public hearing,  and the site-specific control  costs
 were determined not to be reasonable because of high airflow rates.   Older
 pieces of mix equipment frequently have makeshift covers,  and dry
 ingredients are added by open pouring  rather than by closed pumping
 systems.   Thus,  older,  modified mix  equipment may require  higher airflows
 than new mix equipment  to keep  the VOC concentrations  in the work area at
 safe levels (below the  threshold "limit value and  the lower  explosive
 limit).   These  high  airflows  further exacerbate the  problem of  limited
 control  device  capacity.
      The  Agency's  original  analysis  of BDT  and  the mix room standard,at
 propos.al  were'never  intended  to  include the scenario of  controlling the
 entire room ventilation air from the mix room.  The  original  analysis  was
 based on  new mix equipment, which  has  covers that can be easily adapted  to
 ventilation to a carbon adsorber at  low airflows.  After discussions with
 personnel at the two plants submitting comments, the Agency  has concluded
 that retrofitting  this type of low-airflow capture device to existing
 modified  mix equipment is not always technically feasible or cost effec-
 tive.  Therefore,  the Agency agrees that 80T for modified mix equipment
 should be covers instead of ventilation to a 95 percent efficient control
 device.   However,  the Agency still  believes that control  of new mix equip-
 ment can  be achieved at a reasonable cost by carbon adsorption when a new
 control device is  being constructed for other purposes  at the plant and
 the SLA from the mix equipment is considered in the design  of the
 device.   In addition, the Agency believes  that if  covered,  modified or
 reconstructed mix equipment is vented to a control  device,  lower  VOC
emissions would result;  therefore,  this alternative  is  allowed, and no
testing is required in such cases.

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     The standard has been changed  to  require covers,  alone  or with
venting to a control device, on all modified or reconstructed  mix
equipment and on new mix equipment  when there is no  concurrent
construction of a control device on a  coating operation  at the plant  or
when the control device installed concurrently is a  condenser.   If new mix
equipment is installed at a time when  there is concurrent construction of
a control device (other than a condenser) on a coating operation at the
plant, covers must be used on the mix  equipment and  must be  vented to a
control device that is 95 percent efficient.  The Agency selected
95 percent for the control efficiency  because carbon adsorption (which can
achieve 95 percent efficiency) is one  component of the BDT selected for
this industry.  In its review of the operating data  for carbon  adsorbers
in this and other industries, the Agency has concluded that  95  percent is
achievable on a long-term continuous basis for a properly designed device
(see Comment 2.1.1).  Thus, any new carbon adsorber  should be  capable of
maintaining this'level of control.  "Concurrent" has been defined to mean
6 months before or 2 years after the installation of the new mix
equipment.  This period is designated  because it is  consistent  with the
normal planning and purchase cycles for equipment of this type.  The
2-year period also coincides with the  period for which records  required  "
Under this standard must be retained.  A definition  of covers and the
                                                                i
compliance and reporting requirements  for the covers have-been  added to
the regulation.  A cover is defined as a device that (1)  lies over the
equipment opening, (2.) either extends  at least 2 centimeters (crn)
(0.8 in.) beyond the rim of the equipment or is attached  to the rim,
(3) maintains contact with the rim for the entire perimeter,  and (4)  is
opened as seldom as possible.  A nonpermanent cover may be used, if it
meets these criteria.  The notification of actual  startup is the only
reporting requirement; all  other monitoring, recordkeeping,  and reporting
requirements have been waived for plants with only affected  mix equipment
required to install  and use covers.
     2.2.2.2  Comment.  According to one commenter (IV-0-3),  there is.a
strong bias in the Volume I BID toward carbon adsorption  control of mix
room emissions that is unwarranted because of the  problems  that are
encountered with the use of this technology to  recover  some  solvents.   In
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 particular, cyclohexanone is unsuited for carbon bed recovery because of
 potential  hot spot formation that would result in bed fires and plugging
 of the bed by oxidation products.  The proposed mix room standard
 penalizes  manufacturers who select condensation as the coating operation
 control  technology.   According to the commenter,  emissions from new or
 modified mix equipment cannot be added to the condenser controlling oven
 emissions  without upsetting oven control  because  the oven and condenser
 have  a closed-loop,  steady-state air balance that would be disrupted by
 intermittent and  variable airflow and low VOC levels from the mix room.
      Response.  The  Agency reviewed  the available data on types  of solvent
 and associated  control  devices used  in this  industry.   Plants using cyclo-
 hexanone as part  of  a blend  of solvents have successfully controlled mix
 room  and oven emissions with carbon  adsorbers.  However,  those plants
 electing to use pure cyclohexanone have installed condensers  for control
 of oven  emissions.   According  to  one  vendor,  bed  fires  did,  in fact,  occur
 in the one  carbon  adsorber installed  by his  company' at  a  magnetic  tape
 plant  using pure cyclohexanone.6
     The vendors of  condensers used  in  this  industry have agreed with the
 commenter1s  statements  regarding  the  impact  of venting mix room  emissions  •
 to  a closed-loop condenser on the oven.17'18  The moist,  intermittent SLA
 streams  from .mix equipment are incompatible with  finely tuned, closed-loop
 oven/condenser systems.  Use of a separate control device to control mix
 equipment emissions  has been found not to be cost effective.  Based on
 these data, the Agency will allow a different level of control of mix room
 emissions for those plants using a condenser to control coating operation
 emissions.  For such plants, covers that meet specific criteria must be
 used on  the mix equipment to control  VOC emissions.
 2.3  AFFECTED FACILITY AND MODIFICATION AND RECONSTRUCTION
     The following comments are presented individually,  but only  one
response has been  written to reply to all  of  the comments  because the
 issues of affected facility,  modification, and reconstruction  are inter-
related.
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2.3.1  Comment
     Commenters representing  three  companies (IV-D-3,  IV-D-4,  IV-D-20,
IV-D-28,  IV-F-1 [Fischer])  suggested  that the affected facility definition
of the coating operation  standard be  revised to exclude existing equip-
ment.  One  commenter  (IV-F-1  [Fischer])  cited his  company's  experience
that, contrary to  information in the  Volume I BID,  modifications or recon-
structions  to the  mix room  do occur frequently. Another commenter
(IV-D-28) suggested that  EPA  consider applying the  standard  to  new
facilities  only and requiring modified or reconstructed facilities to
comply with the existing  State regulations (see Comment 2.7.1).   A third
commenter (IV-D-3) stated that retrofitting control  to existing  mix equip-
ment is very costly and results in  insignificant emission  reduction.  For
this reason, the commenter  recommends  that existing  unmodified mix
equipment be excluded from  the definition of affected  facility.   This
would focus the regulation  on  new or  significantly modified  installations
where incorporation of new  control  technology could  be accomplished more
economically.  The commenter  said that these issues  were not considered
adequately  in the Volume  I  BID.
2.3.2  Comment
     Commenters representing one company  '(IV-D-1, IV-D-21) said  that
combining the coating application/flashoff  area  and  oven with the  mix- room
in the affected facility definition implies  that controlling emissions
from the two areas is equally  important.  According  to  the commenter, the
NSPS should emphasize control   of the oven because 90 percent of  the
emissions are from the oven.
2.3.3  Comment
     Two Commenters (IV-D-1, IV-F-1 [Fischer]) noted that a minor
modification to the mix room might make both the mix room and the coating
application/flashoff area and  oven subject to the NSPS.  One commenter
(IV-F-1 [Fischer])  noted that  his  company would have to replace its
existing control  equipment completely to meet either a 93 percent overall
level of control  or to demonstrate a 95 percent efficient control
device.   Another commenter (IV-D-1)  said that it would be nearly impos-
sible for an existing facility that  is already highly controlled to use  an
emission offset to  avoid becoming  affected due to a minor mix room
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 modification.   The commenter also stated that it is difficult to determine
 the  "comparable"  capital  value of an entirely new "facility" to determine
 if reconstruction has  occurred when a mix room serves two coating opera-
 tions.   Two  commenters from one company (IV-D-1S IV-0-21) suggested that
 the  affected facility  be  defined as the coating application/flashoff area
 and  oven only,  excluding  the mix room.   Control  of the associated mix room
 could be required only after the coating operation has become subject to
 the  standard.   Thus, according to the commenter (IV-D-1), a minor mix room
 modification would not require the entire coating operation to comply.
 Another  commenter (IV-0-4)  suggested that the affected facility definition
 be revised to require  compliance with the NSPS for only the equipment that
 is modified  and not for the other unchanged  operations (e.g., only the  new
 mix  equipment,  not the coating operation).
 2.3.4  Comment
     Some commenters noted  that it is not unusual  for  coating lines  to  be
 modified or  reconstructed  (IV-F-1 [Sower,  Ford,  Zosel],  IV-D-6)  and  that
 the  additional costs of retrofitting a  coating line  and  controls should  be
 considered (IV-F-1  [Zosel],  IV-D-4,  IV-D-6,  IV-D-28).  Commenters  (IV-F-1  •
 [Sower], IV-D-4)  also  stated'that the trend  in the'United  States is  either
 to go. offshore for production  or to  modify"a.coating line  rather than to
 build an entirely  new  one.  Modernization of  coating Tines was deemed a
 frequent and necessary  occurrence if  the  domestic tape manufacturing
 industry is  to remain  competitive (IV-F-1  [Sower]).  One commenter
 (IV-D-5) stated that the economic analysis should include  an  evaluation  of
 the  impact of the NSPS  on modification and reconstruction.  Other
 commenters noted that the cost  to meet the standard for reconstructed or
 modified lines would be higher  than the cost of incorporating controls
 into new facilities (IV-F-1 [Zosel],  IV-D-28) and that this fact, coupled
with the fact that most of the  facilities affected would be modified or
 reconstructed,  indicates that the proposal preamble understated the costs
of compliance (IV-D-28).
     Six commenters (IV-D-13, IV-D-15, IV-D-17, IV-D-18,  IV-D-20, IV-E-61,
65,  and  82)  submitted  actual or theoretical scenarios for coating line
modifications at their  plants and the necessary control system changes and
costs.   Three of these  scenarios involved changes to the  coating line to
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increase production speed, two scenarios  involved  changes  in  the  mix room
equipment, and one scenario did not specify the type of modification.
Four of the scenarios included the installation of new control  devices  for
the entire modified line.
     Response.  In addition to the six modification scenarios  submitted by
industry (see Comment 2.3.4), EPA surveyed the remaining plants in  the
industry and confirmed that the industry  now believes that growth,  at
least in the next several years, will occur primarily as a result of
modifications to both mix equipment and coating operations.    The  Agency
performed detailed site-specific analyses of the control costs for  the
modification scenarios supplied by industry (Docket Item IV-B-12).20  The
details of these scenarios and the cost analyses will not be presented
here because confidential treatment of all of the  information submitted
was requested by the plants.  Three of the scenarios are likely to  be
actual modifications under the criteria in 40 CFR  60.14.  One scenario  is
not likely to be a modification.  The remaining two scenarios were
entirely hypothetical, and not enough information  could be provided to
make a modification determination despite the Agency's requests for
further information.  However, EPA conducted a cost analysis on the five
of the six scenarios for which sufficient data were-supplied on the       "
assumption that, even if the specific case was not a modification, the
general concept might be valid in other cases.  The cost analyses were
performed for-the control strategies  presented by the commenters and for
alternative strategies.   Each cost analysis was specific for the operating
practices and equipment at the plant.
     The analyses indicated that modified mix  equipment could  require high
airflows that exceed the existing control  device capacity;  therefore, a
new control device would have to be installed  to control  only  the mix room
emissions.   For the two  specific scenarios, the cost  to construct a
separate control device  was not reasonable. As discussed  in the response
to Comment 2.2.2.1, the  Agency never  intended  to-require  control  of total
mix room ventilation.   The analysis had been based  on  covering equipment
to reduce airflow to the control  device to a low level.   However,  this was
found not to be feasible on older,  modified mix equipment.   As a result,
EPA has revised BDT to be covers,  alone or vented  to  a  control  device,  for
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 modified or reconstructed mix  equipment,  for'new mix equipment at plants
 without concurrent construction  of  a  new  control  device,  and for new mix
 equipment at plants with concurrent construction  of a condenser.  The BDT
 for new mix equipment at plants  with  concurrent  construction of a control
 device (except condensers) for a coating  operation  remains  control  by that
 device (see Comment 2.2.2.2).  The  control device must be operated  at
 95 percent efficiency.  Because  the standard  for  mix equipment  is an
 equipment standard, these new  BDT determinations  are also the  new
 standards for the mix equipment.
      The other three scenarios concerned  increasing  the level of control
 on the coating operation after a modification.  The  analyses showed  that
 if the baseline overall  level of control on an existing coating  operation
 prtor to modification is 83 to 88 percent, the cost  to achieve 93 percent
 overall control after modification is reasonable  even  if a new control
 device must be installed.  However,  for the plant with a baseline overall
 level  of control  of 90 percent, the  cost of adding any control equipment,
 even a small  carbon adsorber to control only the  incremental airflow, is
 unreasonable.   Based on  these results, the Agency has revised the
 regulation to  include different standards  for new and modified or
 reconstructed  coating operation's. New coating operations  and modified or
 reconstructed  coating.operations  .with  a baseline overall  level  of control
 less than  90 percent prior  to making the change must still  achieve
 93 percent overall  control  of applied  solvent (see Comment  2.1.2 for the
 justification  of  this  level).   If an existing coating operation can be '
.demonstrated to achieve  90  percent overall  control or better,  it must
 maintain the existing  overall  level  of control  or  93 percent, whichever is
 greater, following  modification or reconstruction.  If, following a
 modification or reconstruction, a new  control  device is installed,  the
 final  standards require  that  the  control device be at least  95  percent
 efficient.  With  the replacement  of  the  control device, only  the
 incremental costs of control  need to be  considered;  these costs  are
 considered reasonable.21  The standards  also  require  that, once .a
 replacement control device is installed, the overall  level of control  be
 maintained at or above the level  demonstrated prior to  the modification or
 reconstruction.  However, if the  overall level of  control demonstrated
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with the new control device is higher  than was previously  demonstrated
with the old control device, then the  higher overall  level  of  control  (up
to 93 percent) becomes the new standard of performance.
     The methods of demonstrating the  baseline level  of  control  prior  to
modification or reconstruction are  (1) the performance tests described in
the regulation or (2) the use of a  total enclosure that  meets  the  new
definition  (see Comment 2.5.1) and  a control device that is-demonstrated
by the procedures in the regulation to be at least 92 percent  efficient.
The Agency considered requiring that the lower overall level of  control
required at modified facilities be  contingent on the demonstration  of  both
90 percent overall control or greater and insufficient control device
capacity to accommodate the increased VOC loading due to the
modification.  However, no practical method was found that  industry and
compliance officers could use to make capacity determinations  easily and
accurately.
     An annual solvent utilization cutoff of 38 m  (10,000 gal)  for
coating lines was included in the NSPS at proposal to avoid unreasonable
control costs at facilities where the incremental emission reduction would
be small.  Because this cutoff was based on costs for new lines, it has
been retained for new coating .operations in the final rule.  However, the
information received from industry on the compliance costs at modified or
reconstructed coating operations prompted a review of the cutoff for these
facilities (Docket Item IV-B-7).22
     Three types of equipment are critical  to meeting the standards:
total enclosures, drying ovens,  and VOC control  devices.   Equipment costs
for modified or reconstructed facilities are  similar to those for new
plants.  The cost of compliance  with the NSPS at  a new facility is that
fraction of the equipment costs  that are in excess of the expenditures
necessary to achieve the baseline level of  control.   However,  in the case
of a modified or reconstructed  facility,  the  entire  cost  of replacement
equipment is ascribed to compliance with  the  NSPS,  resulting in iconsider-
ably less favorable  cost effectiveness.   Industry modification  scenarios
indicated that, depending on  the  design and condition  of  existing equip-
ment, installation or replacement of any  or all of the three types  of
equipment noted above may be  needed  to  achieve compliance.   Eight of the
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 11 coating operations projected to be modified or reconstructed by 1991
 (see Comment 2.7.1)  would be required to increase control efficiency under
 the provisions outlined above.   Based on the information received from
 industry,  it was projected that in order to meet the standards, five would
 need only  to install  total enclosures; one would need a total enclosure
 and a new  drying oven;  one would need a total enclosure and a new control
 device;  and one would need a total enclosure, a new drying oven, and a new
 control  device.  Using  this mix of equipment requirements and the model
 plant parameters and  costs developed  prior to proposal  to compute weighted
 average  costs, it was determined that an annual  solvent utilization cutoff
 of 370 m  (98,000 gal)  is appropriate for modified or reconstructed
 coating  operations.   This cutoff and  associated  recordkeeping and
 reporting  requirements  have been added to the promulgated standards.   Only
 one of the eight projected modified or reconstructed  coating  operations
 mentioned  above is expected to  be  affected  by this cutoff.
      At  proposal,  each  coating  operation and  its  associated mix  equipment
 were defined  as a single  affected  facility.   This definition  was expected
 to result  in  greater  emission reduction  than  would result from separate
 affected facilities for two reasons.   First,  it allowed  the selection of
 common carbon  adsorption  control  (i.e.,  a carbon  adsorber that controls
 both' mix room  and coating  operation emissions) as  BDT, which  would result
 in  93  and  95  percent  control of  emissions from the coating operation and
 mix  room,  respectively.   (A  separate carbon adsorber for mix  room
 emissions  was  found not to  be cost effective.)  Second, the definition
 would  have resulted in greater emission  reduction than would  have resulted
 from  separate  affected facilities because more mix equipment would be
 brought under  the standard  at this high'level of control, i.e., when a
 coating operation was constructed or modified, all new and existing
 associated mix  equipment would become affected.
     As described in the response to Comment 2.2.2.1,  the Agency has    •  '
 revised its BDT determination for mix equipment because it has been demon-
 strated that retrofitting carbon adsorption control to mix equipment may
 not always be technically feasible at a reasonable cost.   As a result of
 the revised standards, emissions from affected coating operations will  be
90 or 93  percent controlled, and emissions from most affected  mix equip-
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ment will  be  about  40  percent controlled through the installation and use
of  covers.  Because the  level of control required by the standard for the
coating operation is more  than twice that required for the mix equipment,
the overall emission reduction will  be maximized when the greatest pos-
sible number  of coating  operations  become subject to the standard.
Therefore, the Agency  has  selected  the affected facility definition that
would maximize the  possibility of modified or reconstructed coating opera-
tions becoming subject to  the standard.   The  Agency has decided to
separate the  coating operation and  mix equipment into two separate
affected facilities.   This  separation reduces the capital expenditure
necessary to  qualify as  a modification or reconstruction.  The following
factors raised by commenters  also were considered in changing  the affected
facility definition:   (1)  interpretation of the regulation,  particularly
compliance, modification, and reconstruction  determinations, is more-
straightforward; and (2) the  possibility is eliminated  that  a  modification
to  one coating operation may  cause an unchanged coating operation to
become affected because they  share common  mix  equipment,  a result that  was
never intended with  the definition at proposal.
     For the mix-equipment affected  facility,  the following possible
definiti&ns were considered:   (1) each piece of mix  equipment'and  (2) all-
mix equipment at a plant.  Under  the  presumption  that the narrowest
definition is the most desirable  because  it will  result  in including the
most modifications and reconstructions and, thus,  the most emission
reductions, the affected facility was defined  as  individual mix tanks.
This definition will also make compliance, modification, and
reconstruction determinations easier  at plants with many pieces of mix
equipment.
2.4  SOLVENT STORAGE TANKS
2.4.1  Comment
     Five commenters (IV-F-1  [Carlson, Fischer],  IV-D-2, IV-0-3, I-V-D-6)
questioned several  aspects of the storage tank cost analysis and proposed
standard.   Comments  were made on the selection of the baseline  tank, the
cost of a pressure  vessel relative to an atmospheric tank, the  safety of
pressure vessels,  the justification  for submerged fill pipes, underground
tanks,  selection  of  BDT,  and the level of the  standard.   The details of
these comments can  be found in the docket entries listed above.

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      Responset   Based on the cost issues raised by the commenters, a cost
 Devaluation was performed.   The details of this cost analysis are con-
 tained  in  docket item IV-B-2.    The new cost analysis demonstrates that
 there is no cost-effective control  technology for solvent storage tanks in
 the magnetic tape manufacturing  industry.   As a result, a notice was
 published  in the Federal  Register on November 25, 1986, withdrawing the
 proposed standard for storage tanks (51  FR 42800).   This notice was
 published  separately  rather  than at the  time of promulgation of the
 revised regulation so that facilities would not needlessly install  tanks
 complying  with the proposed  standard in  the interim between proposal  and
 promulgation.
 2.5   COMPLIANCE  PROVISIONS
 2.5.1  Comment
      Two commenters (IV-F-1  [Carlson], IV-D-1)  requested that  EPA  provide
 the criteria that would  be used  by  the Administrator  to evaluate enclosure
 designs submitted by  industry as  part of complying  with the  alternative
 means of emission limitation.  One  commenter  (IV-F-1  [Carlson]) noted that
 the technologies  for  testing  such a  total  equipment enclosure  do not exist
 or are not practical  and that  the standard  as written  is  riot capable of
 being administered.      .        ' •  •      '               '  •   •    '  •
     Response.  The Agency agrees with the  commenters  that more complete
 criteria for total enclosures.are needed.  Therefore,  total enclosure
 requirements were  developed after a review of air handling techniques
 already in use in  this and other industries.  The suggested physical
 structure of the  total enclosure was developed from EPA's experience with
 enclosures in a wide range of  industries.  The relative positions of ducts
 and openings and  the locations of measurement points were developed from
 this experience and from industrial hygiene measurement requirements.
     The requirements  have been included  in the final  rule.  Those
 enclosures that conform to the requirements will receive automatic
 approval as total enclosures.  An enclosure that does  not conform to the
 requirements may be approved  by the Administrator on a case-by-case basis
 provided that  it  is demonstrated  that all  VOC emissions from the coating
operation are  contained by the enclosure  and vented  to the control
device.   It should be  noted that  the Agency does not intend to  limit the
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 possible configurations of total enclosures.  A total enclosure could
 range from a close-fitting structure around the application/flashoff area
 coupled with the drying oven all the way up to the room (or entire plant)
 housing the coating operation.   Thus., where product quality concerns
 dictate an enclosure under positive pressure immediately around the
 coating operation,  this enclosure may, in turn, be contained within a
 larger, negative-pressure total  enclosure.
      The current requirements and their bases are discussed below.  The
 Agency is continuing its investigation of appropriate requirements for
 total  enclosures and the related procedure  for capture efficiency testing
 using temporary  enclosures.  The most up-to-date guidance  on these matters
 may  be obtained  from the applicable enforcement agency.   If necessary,  the
 total  enclosure  requirements in  the rule will  be revised during the
 required 4-year  reviews.
      The Agency  has  selected average face velocity across  the  natural
 draft openings as the best  indicator of  complete capture.   Natural  draft
 openings are  defined  as  any openings in  the  total  enclosure that  remain
 open during operation of  the facility and that  are not connected  to a duct
 in which- a fan is installed.- An  example of  a natural draft opening is a
 slot where the base  film  (or "web")  enters the  total  enclosure.  The
 inward  face velocity of the enclosure must be sufficient to overcome
 outward  velocity due to dispersive  forces.   Because face velocity cannot
 be measured directly and  accurately  while the enclosure is  in operation,
 the  Agency has chosen to  specify  that  an  average face velocity  be
 calculated using flow measurements  in  the forced makeup air  ducts and the
 outlet ducts.  The American Conference of Governmental Industrial
 Hygienists (ACGIH) recommends minimum  average face velocities of 2,700 to
 3,600 m/h (150 to 200 ft/min) for enclosures around belt conveyors,
 bins/hoppers, and packaging machines, and through paint spray booths.21*
 The Agency has selected an average face velocity of at least 3,600 m/h
 (200 ft/min) as the guideline for natural draft openings in total
 enclosures in this industry.  A  test procedure based on EPA methods is
 included in the compliance provisions of the promulgated regulation for
determination of the average face velocity across the natural draft
openings.
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     It is expected  that most enclosures can easily meet this guideline.
 For  instance,  the  "typical"  model  coating operation developed by EPA for
 impact analyses  prior  to proposal  coats a web that is 0.66 m (26 in.)
 wide.  This facility would  need a  net exhaust from the enclosure of only
 0.30 standard  m  per second  (m3/s)  (650 standard cubic feet per minute
 [ft3/nnn]) to  maintain an average  face velocity of 3,600 m/h (200 ft/min)
 across entrance  and  exit web slots  measuring 1 m by 0.15 m (39 in.  by
 6  in.).  This  can  easily be  accomplished with the exhaust from the  drying
 oven to the control  device,  which  is  expected to be on the order of
 2.6 standard m /s  (5,500 standard  ft  /min).   In the event that an
 enclosure does not meet  this requirement,  the owner or operator can apply
 to the Administrator for approval on  a case-by-case basis.
     When the  static pressure inside  the enclosure is  negative with
 respect to the static  pressure  outside the enclosure,  an inward flow will
 result.  However, the  static pressure  differential  that results in  an •
 average face velocity  of 3,600  m/h  (200  ft/min)  is  so  small  (approximately
 I pascal [Pa]  [0.004 inches  of  water  (in.  H20}j  across a flanged  opening)
 that motion near a- natural draft opening could  be  enough to  overcome  this
 pressure differential, resulting in outward  flow.   For this  reason,  the
 requirements state that  when  the average face velocity is' between
 3,600 m/h and 9,000  m/h  (200  ft/min and  500  ft/min), continuous inward
 flow must be verified during  the determination of average face  velocity by
 observation using smoke  tubes,  streamers,  tracer gases,  or other means
 approved by the Administrator.  Above 9,000. m/h  (500 ft/min), the average
 face velocity recommended by ACGIH when emissions are  actively generated
 into a turbulent area,  the static pressure differential  is high enough
 (approximately 6.5 Pa  [0.026  in. H20]  across a flanged opening) that
 continuous inward flow can be assumed  without verification.2"
     To differentiate a partial enclosure and a total enclosure, it  is
 necessary to limit the  size  of any natural draft openings (e.g., web
 slots).  The Agency has  included requirements in the final rule that
restrict the total  area of the natural draft openings and the locations of
 such openings  with  respect to any source of emissions within the
enclosure.   The maintenance  of a prescribed face velocity through a  large
opening or through  an opening very  near a source of emissions would  not
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 ensure complete capture because of the increased possibility of localized
 airflow patterns such as backwashj channeling, and eddies that could carry
 VOC out of the enclosure.  (There is no need to set size restrictions or
 minimum face velocity requirements for the forced makeup air ducts because
 the purpose of these ducts is to direct air into the enclosure,, and
 sufficient face velocity will be maintained.)  In addition, the frequency
 with which access doors into the enclosure are opened must be kept at a
 minimum.
      The  requirements based on these principles require that the total
 area of all  natural  draft openings not exceed 5 percent of the .total
 surface area of the  total  enclosure's walls,  floor,  and ceiling.   Any
 sources of emissions within the enclosure, such as  the coater,  must be  at
 least four equivalent diameters away from each natural  draft opening-
 (The equivalent diameter of an opening is four times  the area of the
 opening divided by its perimeter.)   Access doors  must be tightly closed
 during process operation.   Brief,  occasional  openings of such doors to
 accommodate  process  equipment adjustments are  acceptable,  but,  if  such
 openings  are routine or if  an access  door remains open  during the  entire
 operation, the access door  must be considered  a natural  draft opening.
 The  average  inward face velocity across the .natural draft  openings  of the
 enclosure  must be calculated  including such access doors.
      The requirements that  natural draft  openings comprise a  maximum of
 5 percent  of the surface area of the  enclosure's walls,  floor,  and
 ceiling is expected  to  be easily met.  The smallest enclosure would be a
 small  structure around  the  application/flashoff area coupled with the
 drying oven.   Entrance  and  exit  web slots measuring 1 m by 0.15 m
 (39  in. by 6  in.) would be  natural draft openings totaling 0.3 square
 meters  (m  )  (3 square feet  [ft2]).  With these natural draft openings,
 an enclosure with a total surface area of 6 m2 (65 ft2) or more would
 meet  the requirement.  Any drying oven alone will  exceed this surface
 area.  Coating operations that require additional  natural draft openings
 (e.g., access doors that are routinely opened) may not meet this
 requirement as readily with such a small  enclosure.   However, such
 facilities can be contained in a larger total  enclosure in which
operators remain during operation of the  facility.   The natural  draft
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 openings in such an enclosure can easily be designed not to exceed
 5 percent of the total surface area.  In this configuration, the small
 enclosure immediately around the application/flashoff area would serve
 as a local  ventilation system to ensure that the VOC concentration
 within the  larger enclosure is maintained at safe levels.  This larger
 type of enclosure also can readily be designed to comply with the
 requirements pertaining to distances between natural draft openings and
 VOC sources and  to the opening of access doors.   Alternatively, the
 owner or operator can gain approval  of an enclosure that does not meet
 the requirements by demonstrating to the satisfaction of the
 Administrator that all VOC emissions from the coating operation are
 contained and vented to the control  device.
      Operation of the total enclosure also must  be monitored.   The  final
 standards allow  the owner  or operator to select  the most appropriate
 parameter to be  monitored,  subject to approval by the Administrator.
      Based  on the preceding discussion,  the  total  enclosure  definition;
 test procedure;  and monitoring,  recordkeeping, and reporting
 requirements described below have been added  to  the  regulation.
      1.   Definition:   A total  enclosure  is a  structure that  is
.constructed  around  a source of emissions  so that  all  VOC emissions  are
 collected and  exhausted through  a stack  or duct.   With a total
 enclosure, there  will  be no fugitive  emissions, only  stack emissions.
 The  only  openings  in  a total  enclosure are forced  makeup air and exhaust
 ducts  and any  natural  draft openings  such as those that  allow raw   .
 materials to enter  and  exit the enclosure for processing.  All access
 doors  or windows  are  closed  during routine operation of  the enclosed
 source.   (Otherwise  they are considered natural draft openings.)  The
 drying oven  itself may  be part of the total  enclosure.   A permanent
 enclosure that meets  the requirements found in § 60.713(b)(5)(i) is
 assumed to be a total enclosure.   (These requirements are discussed
 above.)  The owner or operator of a permanent enclosure that does not
meet the requirements may apply to the Administrator for approval of the
enclosure as a total enclosure on a case-by-case  basis.  Such approval
shall be granted  upon a demonstration to  the  satisfaction of the
Administrator that all VOC  emissions  are  contained and vented to the
control device.

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      2.  Test procedure:  All forced-air inlet ducts to the enclosure
 and exhaust ducts from the enclosure will be tested according to EPA
 Methods 1 or 1A and 2, 2A, 2C, or 2D (40 CFR 60 Appendix A).  These
 measurements will be made to determine (1) the amount of air evacuated
 from the enclosure (or any component within the enclosure) and (2) the
 amount of forced makeup air entering the enclosure.  By subtracting (2)
 from (1), the value of the net airflow into the enclosure through the
 natural draft openings is obtained.  When this net airflow is divided by
 the total area of all  natural draft openings, the value of the average
 face velocity is determined.   These measurements also indicate whether
 the static pressure within the enclosure is positive or negative.   When
 the net airflow is positive,  the enclosure static pressure is  negative
 with respect to the exterior.
      3.  Monitoring, recordkeeping, and reporting:
      The owner or operator must  submit  a monitoring plan  for the  total
 enclosure along with notification of anticipated  startup.   The  plan must
 identify the parameter to be  monitored  (e.g.,  the amperage  of  the
 exhaust fans or duct flow rates)  and the  methods  for continuously
 monitoring the chosen  parameter.   All 3-hour  periods during  Which the
 average monitor readings  vary by  5 percent  or more  from the  average
 value measured  during  the most recent performance test that  demonstrated
 compliance must be reported.
 2.5.2   Comment
     One commenter (IV-F-1  [Haynes]) raised concerns about the technical
 feasibility,  accuracy,  and cost of  conducting the performance
 evaluations  under  the  gaseous emissions options, particularly at plants
with many  coating  lines and multiple-bed carbon adsorbers.  The
 commenter  questioned the  accuracy of measurements taken in a temporary
enclosure  around the coater.  In addition, the commenter questioned the
accuracy of using  a gas chromatograph (GC) to measure the VOC
concentrations of  the multisolvent systems that are commonly used at
magnetic tape manufacturing facilities.   To be accurate,  the GC would
have to be calibrated with a standard gas, the organic content  of which
has a composition very near to that of the gas stream to  be measured;
however, the composition of the gas stream at a magnetic  tape line  can
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 vary over  time.   Changes  in  the  type or ratio of organic compounds in
 the gas  stream to be measured  will  introduce an  error into the
 analytical results.  This  error  will  be increased if the airflow rate of
 the measured gas  stream is large.   The  commenter also noted a  problem in
 determining accurately the total VOC  exiting a multiple-bed carbon
 adsorber because the VOC concentration  in  all  the stacks  would have  to
 be measured and integrated over  time  to determine emissions from the
 recovery plant.   In addition,  the commenter  said  that, for  the gaseous
 compliance tests, equipment would be  required  to  shut down  and purge
 sample lines automatically during desorption cycles  to remove  possible
 water vapor and air.
      Response.   The performance test using gas-phase measurements  for
 determining compliance is based on two  independent measurements that may
 be conducted simultaneously.   One measurement is capture efficiency or
 the efficiency  of' the VOC collection and containment device(s)  around
 the affected facility.   The other measurement is the efficiency of the
 control  device.   The product  of these two efficiency measurements is  the
 total  control system efficiency.
      Capture efficiency  is  defined  as the fraction of all  gaseous VQC
 emitted  from the  affected  facility  that  is  directed to a  control   '
 device.   Mathematically,  it is  the  quantity of VOC directed  to  the
 control  device divided by the sum of that quantity and the fugitive
 emission  losses.   Control device  efficiency is  the difference in mass of
 VOC transported through the inlet and  outlet  streams  divided by the mass
 of  VOC transported through  the  inlet stream during the prescribed  test
 period.
     The  measurement of capture efficiency  is dependent on the  ability
 to  measure  fugitive emissions.  There  are two methodological
 approaches.  One approach would be to  shut  down all other sources of VOC
 that are  located in the same room as the affected  facility and continue
 to  exhaust  the fugitive emissions from the  affected facility through the
 building ventilation system and  other room exhausts such as ovens or
 roof fans.  The  preferred approach is to build a temporary enclosure
 around the coating operation and its VOC capture system and discharge
 the fugitive emissions through a common stack  so that all  fugitive
emissions can be measured simultaneously at  a  single point.

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     A temporary enclosure built to measure fugitive  emissions must be
constructed and ventilated so that it has minimal  impact on the
performance of the permanent VOC capture system.   A temporary enclosure
will be assumed to achieve total capture of fugitive  VOC emissions if it
conforms to the requirements for a total enclosure discussed above and
if all natural draft openings are at least four duct  or hood equivalent
diameters away from each exhaust duct or hood.  (This requirement is
included to avoid drawing air through a nearby natural draft opening
directly into the exhaust duct or hood.  This sort of "short circuit"
could (1) dilute the SLA vented to the control device, (2) allow
stagnant areas to develop within the enclosure where  the VOC concentra-
tion might build up to unsafe levels, and (3) preferentially influence
the face velocities across the natural draft openings..  With a distance
of four equivalent diameters or more between the exhaust ducts or hoods
and the natural draft openings, these potential problems will  be
minimized.  In nearly all cases, a temporary enclosure can readily be
designed to meet this requirement.)  Alternatively, the owner or
operator may apply to the Administrator for approval of his temporary
enclosure on a case-by-case basis.  The development of this capture
efficiency test procedure is ongoing.  Additional   guidance on  the design
of a temporary enclosure may be obtained as indicated above in the
discussion of total enclosure requirements.
     For the performance test, all emission streams including  fugitive
emissions must be transported through ducts or stacks suitable for con-
ducting the gas-phase measurements of flow rate and VOC concentration.
Once this requirement is met, every stream is subjected to the same
battery of sampling and analytical tests.   These tests are EPA methods
that have been prescribed for compliance determinations in numerous
other NSPS.  The EPA has promulgated  these methods with instructions  for
obtaining maximum accuracy and precision.
     Method 25A utilizes a flame ionization analyzer (FIA), which must
be calibrated prior to use by a reference  gas.   For maximum accuracy,
the calibration gas should duplicate  both  the type and ratio of  the VOC
components of the stream to be analyzed.   However, even if  the
composition of the measured gas varies  from that of the calibration gas,
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 the calculated  capture  efficiency should be relatively unaffected.  The
 same degree  of  change  in  the FIA response will  occur for all  streams of
 like composition  and will,  therefore,  cancel  in the ratios used to
 calculate the efficiencies.   Another reason the variability of the VOC
 in the gas streams  is not an issue  is  that the  performance test will
 take place over a period of  hours or,  at most,  days (not months).
 Therefore, any  process  variability  should be  avoided  or anticipated  and
 planned for  prior to the performance test.   Imprecision can be overcome
 with sufficient replications.  Gas  chromatography  is  not the required
 analytical technique for Method  25A, but  the  preceding  arguments on  the
 accuracy and precision of the FIA technique also would  apply to the
 GC.
      Methods 18 and 25 have  been added as possible  analytical   techniques
 and for simultaneous and continuous measurement of  VOC  concentration in-
 VOC emission streams.   The proposed standards specified only Method  25A;
 however,  this is not appropriate for all sites.   In cases where the
 compositions of the streams  to be measured differ markedly  (e.g., the
 inlet  and outlet streams of  an incinerator), Method 18 or 25 will be
 more appropriate.   A'statement indicating which,  method will be  used must
 be submitted  to  the Administrator for approval with the notification of
.the performance  test.  •
     The  cost of Method  25A  and  the  complementary methods for
 determining  the  gas  flow rate will probably range from $6,000 to $10,000
 per stack.  The  cost of  Method 18 or 25 will  be  somewhat higher.  The
 cost of a  temporary  enclosure will vary depending on the complexity of
 the site  and  the design  of the fugitive emission exhaust system.
     In response to  the  commenter's  third  concern,  the presence of  a
 multiple-bed  carbon  adsorber  will  not introduce  significant  error into
 the test results.  The performance testing provisions  in  the promulgated
 standards require  that test runs  coincide  with discrete  adsorption
 cycles.  Each bed  of a multiple-bed  system with  individual exhaust
 stacks is to  be  tested individually.  Equipment  to shut down and purge
 sample lines  automatically when a bed desorbs during a compliance test
 is not needed.   Test crew personnel are always present at a sampling
 point and would  shut down any sampling  lines should it be necessary  to
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do so during a test.  Also,  a bed  would  not be desorbed in such a way as
to direct the steam  into  the exhaust streams of the beds that are
adsorbing.  If residual humidity does pose a problem,  drying agents  can
be used in the sample lines.
     It is the Agency's determination that the test procedure described
above and in the regulation  provides an  accurate means of determining
compliance at a reasonable cost.   In addition,  each owner or operator
has the option of selecting  the  alternative method  of  demonstrating
compliance presented in § 60.713(b)(5),  which  is the installation of  a
permanent total enclosure and the  ventilation  of all emissions  to a
95 percent efficient control  device.   Because  owners or operators
selecting this option must measure only  total  enclosure face velocity
(see previous comment) and the control device  efficiency,  the cost of a
compliance test is reduced.
2.5.3  Comment
     One commenter (IV-F-1 [Haynes])  suggested  that an  alternative means
of compliance for multiple coating lines ducted  to  a single  solvent
recovery system would be a solvent recovery efficiency  based  on a single
plant-wide material balance,.   The  level of  control  required  by the SIP  '
would be used to determine the' baseline  level of control to  be applied
to the solvent use as determined from current tankage and mix and
coating equipment.  The NSPS  level of control would  be  used-  to determine
allowable emissions from solvent use above  that baseline level.  The  two
levels of control would be combined to calculate the single plant-wide
recovery efficiency value.  Compliance would then be shown easily by
records of solvent consumed,  purchased, and discarded.
     Response.   The compliance method recommended by the commenter would
require either that the test  be applied to  a group that includes both
affected and nonaffected facilities or that the affected facility
definition be changed to be the entire plant.
     If the suggested compliance test were conducted at a plant with  one
affected coating line and  multiple nonaffected VOC sources such as other
coating lines,  storage tanks,  and cleanup,  the material balance would
probably not be sensitive  enough to detect the effect of a change  from
83 to 93 percent control of just the affected facility  within the
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  plant.   In  addition, even if the method were sensitive enough, it would
  not  be  possible for the compliance officer to determine if the emission
  reduction occurred at the affected facility or at nonaffected sources.
       Changing  the affected facility definition would overcome these
  problems with  the suggested compliance method.  However,  a narrow
  designation  of affected facility is presumed by EPA to be the best
  choice  because it ensures that  the maximum possible number of
  modifications  and reconstructions  are  brought under the standards of
  performance.   If  the entire plant  were designated as the  affected
  facility, the  minimum capital investment  that would be considered a
  modification for  increases  in production  (about 15 percent of the total
  capital equipment value)  or a reconstruction (50  percent  of the capital
  cost of a comparable new  facility)  would  be  so large that  most changes
  would not bring the  plant under  the proposed standards.  Modifications
  are expected to be more common than construction  of new lines  in  this  •
  industry (see  Section  2.3).  Of  the modification  scenarios  submitted by
  industry, modifications to  increase production  were the most common.
 Thus, changing the affected facility definition to  the  entire plant
'would decrease the emission reduction  achieved  by the'standards.
    " .The suggested compliance method would not  be capable.of  '
 demonstrating that the required  level of control  is being achieved by
 the affected facility.  Changing the affected facility definition to
 accommodate the compliance method would decrease the emission reduction
 achieved by the proposed standards.  Therefore, a plant-wide material
 balance is  not included as a possible compliance method.
 2.5.4  Comment
      One commenter (IV-D-3) suggested that a single standard of
 90 percent  control over the combined mix room and  coating  operation be
 offered  as  an alternative to the separate  requirements for the coating
 operation (application/flashoff  area and oven) and mix equipment.   The
 standard would  be based on percent  reduction  of the solvent entering the
 mix room.  This alternative would simplify measurements  and
 demonstration of compliance.  In  addition,  metering  of solvents is  more
 accurate than metering of  coatings,  as  would  be required for a material
 balance  around  the coating operation alone.
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      Response.   At most magnetic tape plants, mix equipment serves more
 than  one coating operation.   Thus, it would not be possible to perform a
 material balance starting at the mix room that would include only the
 affected facility because all  the solvent entering the mix room during
 the month of the test would  not be mixed in affected mix equipment or
 applied  at the  affected coating operation.   Such a compliance method
 might be possible if all  nonaffected coating operations were shut down
 for the  month of the test; however, this method would be too great an
 interruption of production and would result in abnormal control  device
 operation.   Another way to implement the commenter's suggestion  would be
 to define the affected facility as the mix  equipment and all  associated
 coating  lines;  this definition would result in virtually the entire
 plant becoming  affected.  For  the reasons given in Comment 2.5.3,  the
 Agency concluded that such a change in affected facility definition  is
 not appropriate.   The Agency decided that the level  of  the standard
 should not  be decreased to 90  percent for the reasons presented  in
 Comment  2.1.2.   Because the  suggested compliance method is not feasible
 given the affected  facility  definition and  a level  of control higher
 than  90  percent can be achieved,  the regulation was  not revised  to be a
 single s'tandard of  90 percent  control  across the mix  room  and coating
 operation.
 2.6   REPORTING  AND "RECORDKEEPING  REQUIREMENTS
 2.6.1 Comment
      One commenter  (IV-F-1 [Sower])  stated  that  the  implementation of
 the proposed  standards  would subject his  company  to an  additional  set of
 standards and a third  agency to which  to  report  data.   The commenter
 believes  that this  reporting burden  would be excessive  and suggested
 that  the intent of  the  proposed standards can be  better accomplished  by
 delegating  the  administrative duties  to the  existing State agencies.
      Response.   During  the first  3 years of  implementation, the average
 industry-wide labor burden of this NSPS was  estimated to be 1.5 person-
years  per year,  based on an average  of 4.8 respondents per year.   These
 burdens  are considered  by the Agency to be reasonable.  Under
 Section  lll(c)  of the Act, EPA may delegate enforcement authority to a.
 particular  State.,  In cases where EPA delegates that authority and
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 approves the reporting requirements  adopted  by  such  State,  the  affected
 sources within the State may comply  with the State requirements  in  lieu
 of the Federal requirements.
 2.7  COST AND ECONOMIC ASSUMPTIONS AND  IMPACTS
 2.7.1  Comment
      One commenter (IV-D-32) stated  that the Agency  has not adequately
 addressed the problems associated with the use of ketones by the
 magnetic tape industry.  As stated by the commenter:
      "(We submit) that the considerable daily data provided in these
      supplemental comments—far in excess of anything currently in the
      record—demonstrate the problems caused by use of ketones.   The
      Agency must focus on the environmental and cost impacts of the
      proposal on ketone users before the standards may be promulgated."
 The commenter went on to imply that the variability in carbon  adsorber
 performance is greater when ketones are present in the SLA stream and to
 state that  ketones shorten  the useful life  of the carbon in  adsorption
 systems,  resulting in greater cost impacts  attributable to the  NSPS  than
 indicated by the  cost analysis  carried  out  by EPA prior to proposal.
      Response..
  .    Summary.  As'a result  of this, comment,  the  Agency sought additional
 information  on the effect of  ketones  in  the  SLA  delivered' to a carbon
 adsorber.   Based  on responses by designers of'carbon  adsorber systems,
 carbon manufacturers,  and operators of adsorber  systems, the Agency
 agrees that  ketones are somewhat unique  in that  they  appear to
 accelerate fouling and can  cause elevated temperature  in an adsorption
 bed.  However, neither of these problems would cause extreme variability
 in the efficiency of  an adsorber from cycle to cycle, and carbon
 adsorbers are commonly used at magnetic tape facilities that  use
 ketones.
     Accelerated fouling would decrease the working capacity  of a carbon
 bed, shorten the productive adsorption cycle, and, if the cycle change
 is initiated by time interval, result in an  apparent rapid degradation
 in the recovery efficiency of a carbon bed.   (A more thorough discussion
of this misinterpreted phenomenon  is presented in the  earlier response
to Comment 2.1.2.)  If the adsorber is properly operated,  however,
                                   2-51

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recovery efficiency still can  be maintained  above  95 percent.  'The
accelerated fouling will reduce bed  life  and increase recovery costs
somewhat above those experienced for other organics.  Nevertheless,  the
cost effectiveness of the NSPS relative to the  baseline  control  level
(that required by typical SIP's) is  reasonable  even  when accelerated
fouling occurs.
     Elevated temperatures in  the bed can occur because  of  the
exothermic reaction ketones undergo  on the surface of the carbon.
However, in a properly designed, operated, and  maintained system,  the
heat generated in this manner would  not be expected  to contribute  to a
cycle-by-cycle variation in efficiency or bed-to-bed variation in  bed
life.
     Presented below is a more detailed discussion of the effect of
fouling and elevated temperatures on the efficiency  and  cost of
adsorption control.
     Details.
     Accelerated fouling.  Some ketones (particularly cyclohexanone)
will react on the surface of the ;carbon, forming large molecules that
are difficult to desorb.  The result is-an incremental reduction in  the
working capacity of the carbon wh-ich, when added to  the  normal decay of
working capacity, can significantly reduce the effective  life  of a
carbonl  It is believed by some that use of  "low ash" carbon will
minimize this polymerization.25'26  Low ash  carbon contains little of
the inorganic minerals (e.g., iron)  that are believed, to  catalyze the
reaction.
     In a system where accelerated fouling occurs, the bed life will be
a function of the rate of fouling and the capacity initially designed
into the system.   Although the exact mechanisms of rapid fouling are
poorly understood, the rate is probably dependent on  the type and
quantity of organic in the SLA stream,  the regeneration procedures, and
the type of carbon.  Reports by this industry of bed  lives as brief as  3
to 18 months when ketones are used indicate that the fouling rate is
indeed greater than commonly encountered  when other solvents are used.
     There is some indication that the  increased fouling rate may not be
wholly attributable to ketones.  One manufacturer that controls his mix
                                   2-52

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  room  by  drafting  the mix tanks to the adsorber has experienced fouling
  as  a  result  of  entraining the magnetic medium (iron oxide) into the
  draft to  the carbon  system during additions of the medium to the mix
       2 7
  tank.     The oxide could have a dual  adverse effect,  physically plugging
  the carbon and  catalyzing the polymerization of the ketones.
       Regardless of the  cause,  the rate of  fouling  need  have little or no
  effect on the operational  efficiency  achievable by a  properly  designed
  and operated adsorber.   Figures  2-6 and 2-7  present the  inlet  and  outlet
  concentrations of a  typical multiple-bed carbon adsorber  system shortly
  after new carbon has been  added  and again  shortly  before  time  for  the
  carbon to be replaced.   These two  events will occur at more frequent
  intervals if the bed fouling  is  accelerated, but the rate  of fouling  is
  not a determinant of efficiency, as the subsequent discussion will
  illustrate.
      For illustration purposes,  it will be assumed that the multiple-bed
 system consists  of only two adsorption beds.-  It is not uncommon for
 large  adsorption systems.to consist of three or more vessels.   Such
 configurations can add flexibility to  the  operation of the system.
 However,  the  factors  that .determine bed life.remain the same and are
 adequately'represented by a'two-vessel example.  .        '
     At any time,  only one vessel of a two-vessel  system  is on  line
 operating in  the adsorption mode.  The other is  undergoing
 regeneration.  For  purposes of this example,  it  is  assumed that the time
 required  for  regeneration of an  adsorber vessel  is  60 minutes.   This
 includes  the  hot desorption cycle and  the cooling/drying cycle.   In a
 well-designed system,  desorption  is conducted by a  countercurrent flow
 of steam  through the  carbon bed.   The  duration of steaming  and  the  steam
 temperature are determined  based  on desorption of the maximum quantity
 of the most difficult-to-desorb solvent.  The conditions provided during
 the cooling/drying cycle  must return the carbon bed to the design
 temperature and moisture  content.
     For this example, each bed has been sized to assure a working
 capacity which will permit  a 90-minute  adsorption cycle during
conditions of maximum solvent loading.   Each bed is equipped with a
monitor so that  the adsorbing vessel can be  removed from service (and
                                   2-53

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                                  2-54

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 replaced by the  regenerated  vessel)  when  the  outlet  VOC concentration
 climbs to a predetermined  level,  in  this  example,  100  ppniV.   The vessel
 removed from service  is then regenerated.   It is assumed that the
 volumetric flow  rate  of the  SLA stream  is constant,  that the  maximum VOC
 concentration is 3,000 ppmV,  and  that the typical  VOC  concentration  is
 2,000 ppmV.
      In Figure 2-6, the inlet and outlet concentrations  are plotted
 against time for the  tenth adsorption cycle of a vessel  that  has  been
 recharged with new carbon.   (The first few cycles  are  not representative
 of normal performance because carbon requires a few cycles to equili-
 brate.)  The carbon bed was designed for a 90-minute adsorption cycle
 when the inlet VOC concentration is 3,000 ppmV.  With an inlet
 concentration of 2,000 ppmV,  the same mass of VOC would be vented to the
 adsorber over 135 minutes.  However,  the working capacity will be
 slightly diminished because of the lower inlet VOC  concentration, so the
 adsorption  cycle will  be  greater than 90 but less than  135 minutes.
      Figure  2-6  represents this  adsorption cycle of approximately
 120 minutes  (the exact length is not  critical  for this  example).   The
 short .period of  elevated  outlet  concentration  at the  beginning.of the
 adsorption cycle may be the result of incomplete, cooling and drying  of
 the carbon bed after steam desorption or,  if there  is a common discharge.
 manifold  for both vessels,  may be  the result of  the inability  of  the
 monitor to distinguish between the  outlet concentrations  of the vessel
 going off line and  the vessel  coming.on  line.  Although  it is  avoidable,
 this  period is included in  this example because it  is typical  of actual
 adsorption system operations.  For ease in calculations,  simplifying
 assumptions were  made  about the maximum outlet VOC  concentration at the
 beginning and end of the adsorption cycles of successive beds.   They are
 assumed to be symmetrical  about the changeover points, to have a
 duration of 10 minutes from start to finish, and to  change value at a
 linear rate (have straight sides).  Averaged over the 120-minute
 adsorption cycle from t0 to tfi the efficiency of the  system illustrated
 in Figure 2-6 is 97.4 percent.  If the averaging period  is extended to
 130 minutes  in order to include the excursion in outlet  concentration
during both  vessel changes (a  worst-case  measurement of  efficiency),  the
efficiency declines  only marginally to 97.3  percent.

                                   2-55

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     In Figure 2-7, the performance of the  same  system is  illustrated
for the last adsorption cycle of the carbon bed's  useful  life.   If  only
normal fouling of the carbon bed has occurred, the activity of  the
carbon will have been degraded by oxidation and  physical wear over  a
period of up to 5 years or more.  If rapid  carbon  fouling  related to
ketone use (or other site-specific causes)  has occurred,  it is.likely  to.
have accelerated the degradation to 18 months or less.  At the 'time
depicted, the capacity of the carbon is assumed  to have been reduced to
the point that breakthrough occurs after only 60 minutes of operation  at
the maximum inlet concentration (3,000 ppmV) under the most extreme
conditions that may be encountered.  Because the minimum length of  the
adsorption cycle is now equal to the time required to  desorb the other
adsorber, working capacity can be permitted to decline no  further,  and
the useful life of the carbon is about over.  Notice,  however, that the
outlet concentration during the bulk of the adsorption cycle remains
constant at about 50 ppmV.  The decreased working  capacity with
attendant diminished adsorptive capacity has not affected  outlet
conditions as explained in more detail in Comment  2.1.2.
     Based only on mass loading, the vessel can  now remain  onstream.for a
maximum of 90 minutes at an inlet concentration  of 2,000 ppmV.  (Figure 2-7
assumes 80 minutes.)  Using the same logic discussed earlier, the effi-
ciency of the adsorption system over this period is calculated to be
97.3 percent.  If the averaging period over which  the efficiency is
calculated is increased by 10 minutes (5 minutes earlier and 5 minutes
later) to include 100 percent of the excursions  of outlet concentrations
during two bed changes (worst case), the calculated system efficiency is
97.2 percent.
     The performance test runs and monitoring data averaging periods in
the promulgated NSPS are required to coincide with complete adsorption
cycles.  Thus, 97.3 percent would be the minimum efficiency measured for
this example system under the final  standards.    If this system were
operated to switch adsorber vessels  at an outlet concentration of
500 ppmV, the worst-case efficiency  at the time represented in Frigure 2-7
would be 95 percent.  This example,  which is based  on proper adsorber
design, operation, and maintenance,  makes clear that a carbon adsorption
                                   2-56

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 system can operate  continuously  with  almost any desired efficiency over
 the entire life of  the carbon.
      Cost Impacts of Accelerated Fouling.   Although  reduced  bed  life need
 not affect the efficiency achieved  by a properly designed  and  operated
 carbon adsorption system, it will affect the  cost of operating the
 system.  When the bed life is reduced, the  annualized cost of  carbon
 replacement will increase.  As explained in the  following discussion,
 essentially the same amount of cyclohexanone  will  be vented  to the
 adsorber under the regulatory baseline (the typical SIP) as  under  the
 NSPS,  so the reduction in bed life  (and attendant  increase in control
 costs)  will  also be the same in both cases.  Thus, the cost effectiveness
 of the  NSPS  relative to the baseline .regulation is not changed directly by
 the use of cyclohexanone.
     However,  as suggested by the commenter, the bed  life may be  reduced
 slightly under the NSPS relative  to  the baseline regulations.  This effect
 can be  examined  in two  ways,  as discussed  below.
     The  first approach is that of EPA's preproposal  cost analysis.  In
 that analysis,  a carbon adsorber  efficiency of 95 percent was assumed for
 both the  baseline  and the NSPS control  levels.  The difference  in 'the
 overall control  levels  achieved by. the two  alternatives  was assumed to
"result  from greater  capture efficiency achieved  in the NSPS case  by
 containing tha emissions  from the application/flashoff area that  would  be
 emitted to the atmosphere  in the  baseline case.   The  increase in  the  mass
 of  VOC vented to the adsorber under  the NSPS as a  result  of increased
 capture efficiency (a maximum of  about  10 percent) would  be expected  to
 reduce carbon bed life slightly through a small increase  in the rate of
 fouling and a proportional reduction in the  length of the adsorption cycle
 prior to breakthrough.
     The carbon fouling effect on the bed life would not be great.  For
those plants that use cyclohexanone,  no appreciable change in  the  fouling
rate would occur.  The increase in the  organic.flow rate .to the adsorber
would be comprised primarily of the faster  evaporating solvents  such as
methyl  ethyl  ketone (MEK)  (with  an evaporation rate of about 3.8 relative
                          n Q
to n-butyl acetate = 1.0).    Cyclohexanone,  which is  by  far the "worst
actor"  in accelerated fouling,  has a  very slow evaporation rate  of about
                                   2-57

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0.2, which is almost 20 times  slower  than MEK.28   Increasing  the capture
efficiency in the application/ flashoff area would  result  in  very little,
if any, increase in the capture of cyclohexanone, which  evaporates
primarily in the oven.  The contribution to the overall  fouling  rate  from
the increase in the mass of other compounds reaching the adsorber likely
would not be noticeable.  Consequently, the NSPS will result  in  little  or
no increase over the baseline  conditions in the rate of  accelerated
fouling.  Where cyclohexanone  is not  used, the rate of fouling might
increase slightly, depending on the identity of the fouling component(s)
and the point(s) of generation  in the coating process.   The relatively
high vapor pressure compounds  captured in the application/flashoff area
will normally contribute very  little  to the fouling rate.
     The second effect of an increased mass flow rate to the  adsorber is a
reduction in the length of the  adsorption cycle prior to breakthrough.   In
all carbon adsorption systems,  the carbon gradually loses capacity with
use, and the length of the adsorption cycle prior to breakthrough
decreases.  The carbon must be  replaced when the adsorption cycle reaches
the minimum acceptable length.  Thus, the starting point of the process,
the initial length of the adsorption cycle with fresh carbon, is critical
in determining the bed life.  The reduction in the'initial  length of the
adsorption cycle due to increased capture under the NSPS would be expected
to be approximately proportional to the increase, in the  mass flow rate,  in
this case, about 10 percent.  The absolute magnitude of  the reduction will
depend on the design of the system but normally will not exceed several
minutes.  In a well-designed system,  such  a change will  represent only a
small fraction of the difference between the initial length of the
adsorption cycle and the minimum acceptable length.   The combination of
this effect and the minimal  increase  in the rate  of fouling will  result  in
only a small  reduction in bed  life.
     The commenter implied that the difference  between the  NSPS and
baseline control  levels lies not in capture efficiency but  in  the
efficiency at which the adsorption  system  is operated.   Under  this
scenario,  the capture efficiency would be  constant  under  baseline and  NSPS
control  situations,  but the  efficiency of  the adsorber would  have to  rise
from 85 percent at  the baseline to  95  percent under  the  NSPS.
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       This  scenario,  like the  one discussed  above, would result in a slight
 decrease in  the  carbon bed  life.   The use or nonuse of cyclohexanone has
 no  bearing on  this fact; the  same quantity  of cyclohexanone would reach
 the adsorber under either of  the  control  options.  In addition,  the total
 mass  flow  rate to the  adsorber of all  compounds  would be  identical  in the
 two cases, so  the effects discussed  above would  not occur.   However,
 operation  at a higher  control efficiency  (95  percent)  would  require that
 the adsorption cycle be  ended earlier  than  if  operation were at  a lower
 efficiency (85 percent).  This would reduce the  initial length of the
 adsorption cycle with  fresh carbon, and the bed  life would be reduced
 correspondingly.
      The exact magnitude of the reduction in cycle  length would- be
 determined by a number of site-specific conditions.  However, the majority
 of emissions over the course of a carbon bed's adsorption cycle occurs  at
 the end of the cycle as the solvent front begins to break through the
 bed.  The emission rate rises  very rapidly at this time.  Thus, the length
 of an  adsorption cycle over which 95 percent efficiency is achieved would
 be,  at most,  a few minutes shorter than an 85 percent efficient cycle.
 With a properly designed, operated, and maintained system, this would
 result in only slightly more frequent carbon replacement,  and the- bed life '
 reduction would be  small.
     The cost-effectiveness  implications of  the.small  bed  life  reduction
 under  the NSPS  relative to baseline regulations were analyzed using  the
 "typical" model  line  (developed for the preproposal  cost analysis),  which
 more closely  approximates the  commenter's  situation  than do the other
 model  lines that were developed by EPA.  The cost  effectiveness of the
 NSPS is  least favorable  in cases where  accelerated fouling of the  carbon
 has  already significantly  reduced  the bed  life.  Thus, the baseline case
 used-for this analysis was a system with a 12-month  bed life and an
 overall control efficiency .(combining capture and control device
 efficiencies) of 83 percent.  The  incremental annualized control cost
 (including solvent recovery credits) of the NSPS for the typical model
 coating operation with a 6-month bed life was found to be a net
       2 9
 credit.    The commenter's scenario also was  analyzed for other  model
 lines and cases where accelerated  fouling does  not occur,  and  the  costs
were found to be reasonable.29

                                   2-59

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     The Agency believes that an adsorption system that has been designed,
operated, and maintained adequately for the ketone SLA stream to which  it
is exposed will be able to meet the NSPS while operating with the same
carbon bed for 6 months.  As explained earlier, adequate capacity can be
designed into the system to accommodate any desired bed life.  For those
systems with bed lives shorter than 6 months, the Agency has concluded,
based on the available data, that these systems are underdesigned or
poorly operated or the beds' useful lives are heavily influenced by
blinding from particulates in the inlet stream.  '
     Elevated Bed Temperature.  It is recognized that under certain
circumstances the presence of ketones in the SLA presents the potential
for the development of "hot spots" in the carbon bed.- If ignored, these
areas of elevated temperature could pose a threat to the efficiency of an
adsorption system.
     Certain ketones can react exothermically on the surface of the carbon
bed.  Under normal circumstances, the airflow will carry the heat from the
bed with no discernable effect with bed's operation.  If, however, there
is poor flow distribution within the adsorber vessel, the heat can
increase and, in the extreme, actually ignite the carbon.
     According to the largest domestic manufacturer of activated carbon,
the poor flow distribution necessary for the development of ,a hot section
                                                                  9
within a carbon bed is almost always a- consequence of poor design.   The '
inlet to the adsorber bed has not been properly baffled to assure uniform
distribution of the inlet SLA.  As a result, any effect of the hot spots,
such as early breakthrough, would be present from startup of the adsorber
and would certainly not occur in an erratic or intermittent fashion.
     Bed fires are most likely to occur when the system is restarted  after
a period of downtime (such as a weekend), and then only if ketones are not
properly purged from the system prior to shutdown.   In such a case,  the
exothermic reaction will continue while the system is inoperative but
cannot ignite the carbon because there is insufficient oxygen.   When  the
system is restarted and the SLA stream contacts the hot carbon,  combustion
can begin.  Such a fire would be considered a malfunction as  defined  in
the General Provisions.
                                   2-60

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      In summary, while the presence of ketones  in  an  SLA stream can affect
 the operation and adsorption cycle of a carbon  adsorber,  the  adsorption
 efficiency need not decline in a properly designed  and  operated system.
      Alternatives to Exclusive Use of Carbon Control.   As  the discussion
 above indicates, ketones (particularly cyclohexanone) in  the  SLA  stream
 can affect the useful bed life of an adsorption system.  Although a
 reduced bed life need not affect the efficiency achieved  by the system, it
 will affect the operating costs.  The incremental cost  effectiveness of
 the NSPS relative to the baseline control  level  is reasonable.  However,
 the cost of meeting any standard will  increase with a shorter bed life.
 For this reason, sources which use ketone  solvents might consider other
 control  alternatives.   In the  original  cost analysis,  the Agency examined
 the costs  associated with the  use of a  condenser at a magnetic tape
 manufacturing  facility and  found them reasonable.   Another approach would
 be the  use of -a  device upstream from the carbon  adsorber which would
 remove  all  or  part  of  the organic in the SLA stream that reduces bed
 life.  A condenser  or  scrubber  might be appropriate, depending on the VOC
 content  of the stream.   Another option may  be to change  the coating
 formulation to reduce  or  eliminate the problem solvent.   If fine,
 particulate matter  is  the cause of reduced bed life," filters can 'be  used.
     Carbon adsorption  is a very useful technology  that  can be applied  in
 a  wide variety of situations.  However, other available  control
 technologies may be  less  expensive.
 2.7.2  Comment
     Several commenters (IV-F-1 [Carlson,  Fischer, Sower],  IV-D-3, IV-0-4,
 IV-D-5,  IV-0-6, IV-0-32)  noted that EPA's  projections of growth  in the
 industry (21 new lines by 1990) are out-of-date and that, in fact, 17 or
 18 lines have been shut down,  retired,  or  put on  standby since the
 National Air Pollution Control  Techniques Advisory Committee meeting
 (IV-F-1  [Carlson]).   The commenters claimed  that  because  so many lines are
 no longer in operation, VOC  emissions from  this  industry  have decreased,
 and there is no longer a need  for the NSPS..
     Another commenter (IV-D-28)  presented the results  of an independent
survey of magnetic tape manufacturers, which  indicated  that most  lines
affected  by the standard will be modified or  reconstructed  lines  rather
                                   2-61

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than new lines as asserted by EPA at proposal.  The survey concluded  that
significantly more facilities would become subject to the NSPS than the
20 estimated by EPA.
     Response.  The Agency has confirmed that there are several  lines  that
are not currently in operation.  However, these shutdowns do not prove
that there will be no affected facilities in the next 5 years.   In fact,
as stated by commenter IV-D-28 and by industry representatives at the
public hearing, there will be modifications to existing lines that would
cause additional lines to become subject to the proposed standards (see
Section 2.3).  Also, at least one new facility has been announced, and
other firms have made inquiries of EPA that suggest additional new
facilities are under serious consideration.  Following the public
hearings, six modification scenarios were provided by industry (see
Section 2.3).  The EPA determined that three of these are likely to meet
the criteria given in 40 CFR 60.14 and would be actual modifications.  The
EPA conducted its own survey of the industry for information on plans to
                                             1 9
construct new lines or modify existing lines.
    • Based on this new information, the projected number of coating lines
to become affected by the fifth year of applicability (1991) has been
revised downward from 21 to .16.  Of these,' 5 will be new and 11 will  be
modified or reconstructed.  However, one new line and two modified lines
will fall below the applicable minimum annual solvent utilization cutoffs
and, thus, would not be required to control  emissions under the promul-
gated NSPS.  In addition, under the promulgated standards,  two of the
modified and reconstructed coating operations are not expected to be
required to increase control efficiency.  In summary,  16 affected lines
are expected in the next 5 years, of which 11 will  be required to increase
their level of control; the remaining 5 lines will  be subject only to
monitoring and reporting requirements.
     Although several firms have exited from the industry in recent years
because of depressed market conditions, other firms in the  industry are
engaged in improving their existing technology and  expanding production to
reduce their production cost.  Interestingly,  most  of  the projected
affected facilities represent modifications  designed  to  increase  the
production capacity and line speed of the production  line.   The  increased
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  interest in modification of existing  lines  is  a  response  to the highly
  competitive environment in the magnetic tape industry where survival
  depends upon reducing production costs.  While the  entry  of new firms  or
  the construction of new lines are not likely because of prevailing market
  conditions, the modification of existing lines to reduce  production costs
  and remain competitive are sustaining forces which  are reflected  in the
  market.  The reduction in nationwide VOC emissions  due to the standards  in
  the fifth year after promulgation is expected to be about 960 Mg
  (1,060 tons).   Thus, the decline in the number of plants manufacturing
 magnetic tape  does not negate the need for the NSPS.
      The Agency believes that the current growth projection is reasonable
 based on the information at hand.   Of course,  economic conditions are
 always changing,  and industry growth patterns  will  change concurrently.
 While future changes may result in  impacts  somewhat  different from those
 now estimated,  this NSPS is expected to  remain  cost  effective with reason-
 able economic  impacts  even  in  the face of  these changes.
 2.7.3  Comment
      Three  commenters  (IV-F-1  [Carlson,.Zosel],  IV-D-5,  IV-D-6)  noted  that
 industry-wide emissions  have not increased as projected  in the Volume  I
 BID;  instead, industry has  reduced VOC emissions  as  a result of .increasing
 the packing density of information bytes and/or reducing coating thickness
 (and  solvent consumed) per  unit of tape produced.  One commenter '.(IV-F-1
 [Carlson]) stated that because decreased emissions have resulted in
 decreased cost effectiveness, the costs of controls  should be reevaluated.
     Response.   No  data have been received supporting the contention that
 VOC use per unit of tape has decreased.  However, even if this is the
 case, total VOC emissions from the industry may not decrease.  According
 to  industry representatives, some new lines will be built and modifica-
 tions of existing lines will occur in this  industry.   Of  the modification
 scenarios received, the most common  is an increase in production  (see  Com-
ment 2.3.4).  Thus, any decrease in  VOC use  per  unit  of tape  may  be offset
by  increased tape production.
     In any case,  a net decrease in  emissions from this industry  would  not
negate the impact  of the  NSPS.   Construction  of  new lines  and modification
of existing  lines  will  bring about 16 lines under  the standards in  the
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next 5 years (see Comment 2.7.2), and the level of control of  1.1  of  these
lines will be raised from the baseline of 83 percent to 93 percent.   In
addition, the proposed NSPS included an annual  solvent use cutoff below
which the cost to install a control device is not reasonable.  This  cutoff
was discussed at proposal and has been retained for new coating opera-
tions.  A higher cutoff has been added for modified or reconstructed
coating operations.  Thus, the evaluation of control costs for lower  VOC
emission rates has already been performed and the Agency does not need to
perform another evaluation.
2.7.4  Comment
     Two commenters (IV-F-1 [Ford]), IV-D-5) stated that the economic
assumptions and forecasts contained in Chapter 9 of the Volume I  BID  are
not representative of the economic situation and price competition faced
by the domestic magnetic tape manufacturing industry today.  One  commenter
(IV-F-1 [Ford]) was particularly concerned that the references in Chapter 9
are not more current than 1983 and requested that the-economic assumptions
and forecasts be reevaluated prior, to promulgation of the standard.
Another commenter (IV-D-13) stated that the proposed NSPS will have a.
negative impact on the domestic magnetic tape industry.
     One commenter (IV-D-28)" contended that, contrary-tb EPA's position,
the regulation would have negative economic impacts.  The commenter
disagreed with the Agency's conclusion that solvent recovery credits would
more than offset the NSPS compliance costs, creating a net cost savings.
The commenter1s own survey of eight plants indicated that savings in new
solvent purchases resulting from recovery and reuse of spent solvent from
the incremental VOC controls necessitated by the NSPS were not sufficient
to offset the total annualized costs of the proposed regulation.   Thus,
the commenter concluded that the regulation would create net compliance
costs for the industry.
     Response.   The economic impacts of the promulgated NSPS have been
recalculated since proposal using information received  from industry and
current market prices.   This recalculation has resulted in revised impacts
but no change in the conclusion that the economic impacts  are neglig-
ible.  The actual impacts may differ from those now estimated as  a result
of the ever-changing economic climate.   These changes  are  not expected to
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 alter  the conclusion that the standards  will  have  negligible economic
 impacts.
      Generally, new coating lines  subject to  the NSPS will  experience a
 savings due to solvent recovery credits.  An  exception exists  for small
 lines  for which these credits may  not completely offset the  cost  of
 control.  As a result, .an annual solvent use  cutoff of 38 m3 has  been
 established below which coating operations are subject only  to
 recordkeeping and reporting requirements.  This cutoff was discussed  in
 the proposal preamble and has been retained in the promulgated standard.
 For small coating lines above this cutoff, the actual and relative cost
 increases are insignificant compared to the current production costs  and
 retail  prices.   If all  cost increases were passed through to the consumer,
 the retail  price increase is predicted to be less than 0.5 percent.
      Modification or reconstruction of coating lines typically results in
 increased production and,  thus,  reduced  production  costs.   However,
 because these changes may  also  increase  emissions,  additional control
 costs will  be incurred  that  will offset  some of the reduction in  produc-
 tion costs.   To  evaluate the probable production  cost  and  price impact of
 added controls on  modified  lines, the Agency analyzed  several different
 cost and  production  line modification scenarios that-were  submitted.by
 industry.  Because of the  limited data provided and  its confidential
 nature, it was not possible  to analyze the'direct effect of compliance
 with the  NSPS on actual production  costs after modification.  It was only
 possible  to calculate the change in control costs that would result from-
 the  regulation and estimate the impact of these costs on retail prices.
 For  the four different products manufactured at the plants that provided
 information, the average per-unit control cost  increases range from less
 than $0.01 to $0.06.    As a percentage of retail  prices,  the resulting
 cost increases represent less than  0.5 percent.  Such increases are not
 expected to-have a significant adverse effect on  the industry.
 2.7.5   Comment
     One commenter (IV-D-28)  pointed out  that this decade  has  brought
dramatic changes  to the  magnetic  tape industry. The domestic  industry's
market  share has  fallen, while  the  retail  price of tape has declined
sharply.  The combination of  these  two factors  has caused retail price  to
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become a key factor in this competitive industry with the result that
retail price is much less elastic now than it was a few years ago.  This
fact makes it difficult for domestic producers to pass on to their
customers price increases necessitated by the NSPS.  Any increase in
retail price places domestic producers at a disadvantage to the foreign
competition and increases the foreign share of the market.  The commenter
stated that, because offshore facilities are subject to less environmental
regulation than those in the U.S., driving the industry offshore would
also result in a net detriment to the environment.
     Another commenter (IV-D-4) concurred that an already shrinking margin
of profit would be reduced further by foreign competition that is not sub-
ject to the regulations and that the proposed regulations would accelerate
the trend of exporting coating lines offshore.  A third commenter (IV-F-1
[Carlson]) noted that foreign competition would not be subject to the
limits on technological innovation as would domestic manufacturers subject
to the proposed standards, while a fourth commenter (IV-D-20,)  stated that
his company would build a new line offshore rather than add further
control on an" existing line modified under the proposed NSPS.
     Response. .Foreign competition-is an: important element in the
magnetic tape industry.  During recent years, depressed market prices have
discouraged the domestic development of new production lines or the entry
of new firms in the industry.  Lower prices also have encouraged the exit
of other firms from the industry and the modification of existing lines to
reduce production costs.
     Because the NSPS has an insignificant impact on new lines and  has
little impact on production costs* it is doubtful  that the  NSPS for new
lines would disadvantage U.S. producers relative to their  competitors.
With modified lines, some additional  control  costs may have  to be
incurred, but even these are insignificant and the other production  cost
reductions obtainable from modifications are  expected  to far outweigh any
additional cost of the added controls.   In addition,  recent  changes  in  the
foreign exchange rates that would  tend  to  discourage  imports and  encourage
U.S. exports should improve the competitive position  of  domestic
producers.
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       Environmental regulations are only one of the many factors that must
  be weighed in determining the comparative advantage of one country over
  another in the production and marketing of products in international
  markets.  Based upon the evidence to date, however, the economic impact of
  the NSPS on the ability of domestic producers to compete in the interna-
  tional  market is negligible.
       Most of the companies in this industry are large multinational
  companies with annual  revenues and assets  in excess of $1  billion
  (Table  9-13 pp.  9-27 and 9-28 of  Volume I  BID).   These companies each have
  a minimum of several  hundred  million  dollars of  long-term  debt.   Even the
  most  costly investment for new or modified lines  would not  increase the
  debt  loadings of the  companies by more  than  1  percent.   Furthermore,  with
.  the recent decrease  in interest rates,  a greater  supply  of  investment
  funds at lower cost  is now available, thus  improving the affordability  of
  new investments.
      The promulgated standards do  not affect or limit  technological
  innovation.   All  products  known to be manufactured in  the magnetic  tape
  industry can  be  coated  in  a total  enclosure.  The use of a total enclosure
  does-not affect  coating composition or necessitate changes in other
  aspects  of the production  process.
      The combination of the factors discussed above indicates that the
  cost to  comply with the NSPS would not drive the industry offshore.
  2.7.6  Comment
      A commenter (IV-D-28) representing  an  industry trade organization
  submitted information on an independent  survey of  the  magnetic tape  manu-
 facturing industry.  Survey forms  were sent to  12  companies  that  indicated
 a willingness to  participate,  and  six  of these  firms,  representing eight
 plants,  responded.  The information included  an economic  impact analysis
 of the proposed NSPS  that was  based on the  survey  results.  The major
 conclusions drawn by  the commenter from  the results of  this survey and
 analysis that are not  discussed elsewhere are presented below.
     The commenter stated  that  the  NSPS would result in significant  costs
 in the form of increased  VOC control'expenditures and reduced investments
 in innovations designed to  enhance  economic productivity.  Based on extra-
 polation of survey  findings, the commenter estimated that cumulative
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capital costs would total $38.1 million  industry wide  through 1991,  with
associated net annual operating costs reaching $2.6 million  in 1991.
Thus, the commenter estimated total annualized costs (annualized  capital
costs plus operating costs) of $9.2 million in 1991.   The  commenter  also
contended that the NSPS would not pass EPA's criterion of  cost effective-
ness in 4 of the 5 years subject to analysis.  The commenter  estimated  the
fifth year (1991) annualized cost per ton of VOC emission  reduction  to  be
$1,816 for 2,452-total estimated tons of reduced emissions.   This  value is
higher than the value alleged by the commenter to be the maximum  criterion
used by EPA for NSPS ($1,075 per ton).  Furthermore, the commenter stated
that, because nearly all of the anticipated reduction  in emissions
resulting from the NSPS is expected to occur in areas  that have already
attained EPA's ambient air standards, the reduction would  be  less  valuable
in terms of environmental benefit.
     The commenter believed the survey results demonstrated the potential
for significant impacts in the form of financial  hardship  for  domestic
plants (if costs are not passed on to the consumer) and reduced interna-
tional competitiveness (if costs are passed on to the  consumer).   If the
increased costs are absorbed by the industry,  the commenter felt that' the
regulation would have an adverse- impact on profitability and  investment
potential.  If, on the other hand, the increased  costs are borne by the •
consumer in the form of higher prices, this would result in smaller, market
shares and fewer jobs for the domestic industry.   The commenter concluded
that in either case, there are significant factors that fall  within the
definition of "major rule" in Executive Order  12291,  and questioned EPA's
position that the proposed rule is not a major rule.
     Response.  As indicated in the response to Comment 2.7.2, EPA has
conducted a new survey of the growth plans in  this industry since the time
the regulation was proposed.  This survey agreed  with  the survey conducted
by the commenter in that,  over the next 5 years,  there  is likely to be
more modification or reconstruction of existing lines  than construction of
new lines.  Subsequently,  a new cost analysis  was  carried out which
resulted in a change in the levels of control  required  for some modified
and reconstructed coating  operations and  for most  mix equipment (see
Section 1.1 and Section 2.3).   The revised NSPS takes  into account the
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  greater expense of retrofitting modified or  reconstructed  facilities.
  Because the commenter's economic analysis was  based  on  the proposed
  standards and not on the revised ones, the results of the  commenter's
  analysis are no longer applicable.  Not enough data  were submitted to
  allow a determination of whether the changes included in the commenter's
  analysis would legally qualify as modifications and  reconstructions,
  whether the incremental control measures and costs claimed to be required
  were realistic,  or what effect the revisions to the  standards would
  have.  Because the commenter's study did not raise any significant new
  concerns that were not addressed by the revisions already made to the
  standards,  it was  determined that the level  of effort required to verify
  the costs  and adjust  the  survey results to  reflect the revised NSPS was
  not justified.   The Agency's new economic analysis,  based on the revised
  NSPS, indicates  that  the  standard  is  cost effective  and  will  result in  an
  industry-wide net  credit of  $32,000 per year  in 1991.
       The Agency  does  not agree  with the commenter's  allegation that the
  anticipated emission  reductions  due to  the NSPS are environmentally less
  valuable simply,  because they are .expected to  occur primarily  in  attainment
.  areas.  The cost-effectiveness value considered reasonable  for an NSPS  for
  this  industry  ($l,200/Mg [$l,100/ton]) was determined in the context of  a
  national standard for an entire class of sources without consideration of
  local air quality conditions.  Thus, when source-specific air quality and
  related public health considerations are important factors  (e.g., in
  nonattainment areas and in prevention of significant deterioration [PSD]
  permitting activities), the cost-effectiveness value that would be
  considered reasonable would be expected to exceed the value determined for
  the NSPS program (see  Comment 2.8.2).   Also,  VOC emitted  in some  attain-
 ment areas can be transported to nonattainment areas,  adding to the  air
 quality problems  experienced  there.
     'The EPA maintains its  position  that this  rule  is  not a  major rule
 based on the three  criteria required to  meet this classification.  First,
 the new economic  analysis conducted by  the Agency has  verified that
 industry-wide  annualized costs are less  than $100 million.   As previously
 stated,  it  is  estimated  that  the  standard would  result in a  net credit of
 $32,000  per  year  in  the  fifth  year.  Secondly, the revised economic
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analysis showed that no significant increase in retail price is expected
as a result of the standard; therefore, it would not be considered a
"major increase in costs or prices" as specified in the second criterion
in the Order (see Comment 2.7,4).  Thirdly, the revised economic analysis
did not indicate any significant adverse effects on competition, invest-
ment, productivity, employment, innovation, or the ability of U.S. firms
to compete with foreign firms (see Comment 2.7.5).
     In summary, since proposal of the standard, the Agency has considered
the higher costs of retrofitting modified or reconstructed facilities to
comply with the standards, and revised the regulation accordingly.  Even
assuming the increased control costs of the NSPS presented in the com-
menter's study and the decreased prices and competitive market conditions
facing the industry are applicable, the conclusion that the proposed rule
is not a major rule is still correct.  Using the commenter's estimates,
the costs to the industry that result from the regulation ($9.2 million
total annualized costs) are considerably less than the $100 million
criterion, and the subsequent production cost and product price increases,
assuming full costs are passed through to the consumer, remain small.
Consequently, the net impact of the regulation on the domestic industry's
ability to compete is also likely to be minimal.
     Based on the data presented in the commenter's study, percentage
increases in retail product prices were calculated.    These calculations
indicate that increases in retail prices of less than 1 percent would
occur for most products and scenarios (maximum price increase of 1.52 per-
cent) if all costs are passed through to the consumer.  This illustrates
that, even assuming the commenter's data are still applicable under the
revised regulation, the cost and price effects of the NSPS are relatively
insignificant.
2.8  SUSPENSION OF THE STANDARDS
2.8.1  Comment
     Four commenters (IV-F-1 [Zosel], IV-D-5, IV-D-6, IV-D-32)  questioned
the need for an NSPS for the magnetic tape industry and suggested either
that the NSPS be suspended pending a thorough revaluation or rescinded.
This argument is based on the decrease in VOC emissions due to fewer
coating lines and thinner coatings, the reduced growth projected for the
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 industry, and the relatively small share of  total  national  VOC emissions
 originating from magnetic tape manufacturing facilities  (see
 Comments 2.7.2 and 2.7.3).             ••
      Response.  Because the magnetic tape manufacturing  industry  is  a
 subcategory of the industrial paper coating  industry, which  is  ranked
 fourth on the NSPS Priority List (40 CFR 60.16), the Clean Air  Act
 authorizes EPA to promulgate standards.  The priority list ranks  major
 source categories according to criteria specified in Section lll(f)  of the
 Act.  One of these criteria is "the extent to which each pollutant
 endangers public health or welfare."   Volatile organic compounds, with
 nitrogen oxides, are precursors to the formation of ozone which is well
 established  as having adverse effects on  health and welfare.
      New source performance standards required  by Section 111 play a
 unique role  under the Clean Air Act.   The  main  purpose of NSPS is to
 require new,  modified,  and  reconstructed  sources to reduce emissions to
 the level  achievable  by the  best  technological  system of  continuous  emis-
 sion reduction.   Congress recognized  that  establishing  such  standards
 would reduce  potential  increases'in air pollution from  new sources,
 thereby improving  air quality as  the  industrial  base  is replaced over the
 long term.  The  role  of NSPS  in achieving the goals set forth  in the  Act
 is  distinct from that of other regulations.
      For the reasons  discussed in Comments 2.7.2  and  2.7.3, the  Agency has
 determined that the NSPS will have a favorable impact on VOC emission
 levels  despite a lower  growth projection and  the  possible decrease in VOC
 use  per unit of tape.   Because the standard will  have a favorable environ-
 mental  impact and reasonable cost and economic impacts, the proposed
 standard will not be  suspended or rescinded.
 2.8.2  Comment
     One commenter (IV-0-4)  stated that the existing State regulations, at
 least in the Bay Area of California,  are sufficiently stringent and that a
 new NSPS is not needed.
     Response.  State requirements serve a  different but complementary
role to NSPS.   State  requirements  are  designed to protect  local  air
quality values and to ensure that  air  quality  does not significantly
deteriorate.   These requirements may vary according  to air  quality
                                   2-71

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conditions in the specific area of the plant whereas NSPS provide a

uniform nationwide minimum requirement based on BDT for a particular

emission source category, irrespective of local air quality conditions or

values.  Uniform nationwide standards increase the total emission

reduction achieved by an industry by discouraging the preferential

construction of plants in States with the least stringent regulations.

     The VOC regulations in California are more stringent than the

baseline used in the analysis of this industry.  However, the regulations

in all other States generally require a level of control of 83 percent or

lower.  The NSPS would set a new floor of 93 percent control for facili-

ties subject to its provisions and, thus, reduce nationwide emissions from

this industry.  Therefore, the Agency believes there is a need Ifor the

standards.  Of course, State and local agencies are free to require more

stringent control as dictated by the needs of specific locations subject

to PSD or new source review regulations.

2.9  REFERENCES FOR CHAPTER 2

 1.  Telecon.  Edgerton, S., MRI,  with Hardaway, C., IBM Corp.  October 6,
     1986.  Information on carbon  adsorber installation and'performance.  .

 2.  Telecon.  Edgerton, S., MRI,  with Miller, K.,.3M Company.  August 15
     and 19, and September 2, 8, and 22, 1986.  Information on carbon
     adsorber, installation and performance.

 3.  Memorandum from Edgerton, S., MRI,  to Magnetic Tape Project File.
     April 2, 1987.  Summary of information  related to 3M adsorber
     performance.

 4.  Telecon.  Beall, C., MRI, with Reber, R. and  R.  Selznick, Baron
     Blakeslee, Inc.  August 26, 1986.  Information on carbon  adsorber
     design and performance.

 5.  Telecon.  Beall, C., MRI, with Wuyts, R.,  Sutcliffe Speakman,  Inc.
     September 3, 1986.  Information on  carbon adsorber design and  perfor-
     mance.

 6.  telecon.  Edgerton, S., MRI,  with Surratt,  R.,  Met-Pro.   August 7,
     1986.  Information on carbon  adsorber performance and  monitoring.

 7.  Letter and attachments  from Fritz,  D.,  Sony Corp.  of America,  to
     Potter, J., EPA/OAR, and Farmer,  J.,  EPA/ESD.   April 3, 1987.
     Supplemental comments on proposed NSPS.
                                   2-72

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  8.  Barnett, K. W., P. A. May, and J. A. Elliott  (Radian  Corp.).   Carbon
      Adsorption for Control of VOC Emissions:  Theory  and  Full  Scale
      System Performance.  Final Report.  Prepared  for  U. S.  Environmental
      Protection Agency.  Research Triangle Park, North Carolina.   DCN
      No. 88-239-003-20-11.  June 6, 1988.  83 p.

  9.  Memorandum from Barnett, K., Radian Corp.., to Carbon Adsorber/
      Condensation Project File.  February 29, 1988.  Minutes of
      November 12, 1987, meeting with Calgon representatives  and followup
      telephone conversation on December 11, 1987.

 10.  U.  S.  Environmental Protection Agency.  APTI Course 415:  Control of
      Gaseous Emissions.  EPA 450/2-81-005.   Research Triangle Park  North
      Carolina.   December 1981.  p.  5-13.

 11.  Reference  8, p.  5-14.

 12.  Magnetic Tape Manufacturing  Industry—Background Information for
      Proposed Standards.   U.  S.  Environmental  Protection  Agency.  Research
      Triangle Park,  North  Carolina.   Publication  No.  EPA-450/3-85-029a
      December 1985.  Appendix  C.

 13.  Letters  and  attachments  from Smith,  C.   Law  Firm of  Arent   Fox
      Kinter,  Plotkin and Kahn,  to Farmer, J.,  EPA/ESO.  September  24 and
      October  22,  1987.   Supplemental response  to  the  Section  114
      information  request concerning Sony's carbon adsorption  system.

.14.   Calgon Corporation, Activated Carbon Division.   Toluene  Adsorption on
      BPL Activated -Carbon, 23-7115.    • .  •     '  .,        -       •

 15.   Goodste.in, S., T.  Flachmeyer, and C. Wickersham.   Solvent Recovery
      Combines with Catalytic Incineration to Effectively Control Fumes
      Chemical Processes.  Mid-November 1985.                           " •

 16.   Memorandum from Berry, J., EPA/CPB, to Wyatt, S., EPA/CPB.  June 2
      1986.  Minutes of May 7, 1986,  meeting between.industry and EPA
      representatives.

 17.   Telecon.  Cassidy, M., MRI, with Memering, L.,  United Air
      Specialists.  November 11, 1986.   Information on condensers.

 18.  Telecpn.  Cassidy, M., MRI, with  Rieman,  D.,  Arco Industrial Gases
     November 11, 1986.  Information on condensers.

 19.  Memorandum from Edgerton,  S., MRI, to Magnetic  Tape Project  File.
     April  17, 1987.  Revised industry growth  projection and applicability
     of the  revised NSPS to the projected  lines.

20.  Memorandum from Edgerton,  S.  and  C. Beall, MRI,  to  Magnetic  Tape
     Project File.  May 11,  1987.  Modification/reconstruction control
     costs—analyses of industry modification  scenarios.
                                   2-73

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21.  Memorandum from Friedman, B., MRI, to Magnetic Tape Project File.
     August 8, 1988.  Cost effectiveness of replacement control devices.

22.  Memorandum from Edgerton, S., MRI, to Magnetic Tape Project File.
     March 5, 1987.  Determination of solvent utilization cutoff for
     modified or reconstructed coating operations.

23.  Memorandum from Beall, C., MRI, to Magnetic Tape Project File.
     June 30, 1986.  Final solvent storage tank control cost analysis.

24.  American Conference of Governmental Industrial Hygienists.
     Industrial Ventilation—A Manual of Recommended Practice. : 19th edi-
     tion.  Edwards Brothers.  Ann Arbor, Michigan.  1986.  pp. 4-5, 5-37,
     5-39, and 5-74 to 5-77.

25.  Miller, K., C. Noddings, and R. Nattkenper.  Preventing Bed Fires in
     Carbon Adsorption Systems.  For presentation at the 80th Annual
     Meeting of APCA, New York, New York.  June 21-26, 1987.  pp.  2-3.

26.  Kenson, R. E.  Recovery and Reuse of Solvents From VOC Air
     Emissions.  Environmental Progress.  Vol. 4, No. 3.  August 1985.

27.  Memorandum from May, P., Radian Corp., to Grumpier, D., EPA/CPB.
     January 15, 1988.  Report on site visit to Capitol Magnetic Products,
     Winchester, Virginia.

28.  Eastman Chemical Products, Inc.  Kodak Solvent Selector Chart.
     Publication N'o. M-167E.  ,'December i976.            •   ,

29.-  Memorandum from Edgerton, S., MRI, to Magnetic Tape Project File.
     June 13, 1988.  Cost effectiveness of the NSPS at various .bed  lives.

30.  Memorandum from Edgerton, S., MRI, to Magnetic Tape Project File.
     January 25, 1988..  Fixed-bed carbon adsorber bed lives of less than
     6 months.

31.  Memorandum from Gillette, D., EPA/EAB, to Dowd-Monroe, C.,  EPA/SDB.
     November 17, 1986.  Comments/revisions of revised BID and Preamble
     Volume II for the Magnetic Tape.

32.  Memorandum from Gillette, D., EPA/EAB, to Dowd-Monroe, C.,  EPA/SDB.
     April 27, 1987.  The magnetic tape industry "survey."
                                   2-74

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                                    TECHNICAL REPORT DATA
                            /Please read Instructions on the reverse before comoletin^/
 I. REPORT NO.
 EPA-450/3-35-029b
                                                            13. RECIPIENT'S ACCESSION NO.
A. TITLE AND SUBTITLE
 Magnetic  Tape Manufacturing  Industry—Background
 Information  for Promulgated  Standards
                                                            5. REPORT DATE
                                                                          July 1988
              6. PERFORMING ORGANIZATION CODE
7, AUTHOR(S)
                                                            8. PERFORMING ORGANIZATION REPORT NO
9. PERFORMING ORGANIZATION NAM6 AND ADDRESS

 Office of  Air Quality Planning'and  Standards
 U. S. Environmental  Protection Agency
 Research Triangle Park, N.C.  27711
                                                             10. PROGRAM ELEMENT NO.
              11. CONTRACT/GRANT NO.
                68-02-3817
 12. SPONSORING AGENCY NAME AND ADDRESS
 DAA for Air  Quality Planning and  Standards
 Office of  Air  and Radiation
 (J. S. Environmental  Protection Agency
 Research Triangle Park, N.C.  27711
                                                             13. TYPE OF REPORT AND PERIOD COVERED
                Final
              14. SPONSORING AGENCY CODE

                EPA/200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
       Standards of performance for the control  of VOC emissions  from magnetic tape
 .manufacturing lines  are being promulgated  under authority of  Section 111 of the
  Clean Air Act.  These  standards apply to all  new magnetic tape  coating lines using
 •at  least 38 cubic meters of-solvent per year  (m /yr) in the production of'magnetic
  tape and to3all modified and  reconstructed magnetic tape coating  lines using at
  least 370 m /yr in the  production of magnetic  tape.  This document  contains a
  summary of the public comments on the proposed standards and  EPA's  responses,  as
  well  as summary-economic and  environmental impact statements.
                                KEY WORDS ANO'DOCUMENT ANALYSIS
                  DESCRIPTORS
                                              b.IDENTIFIERS/OPEN ENDED TERMS  C.  COSATI Held/Group
 Air Pollution
 Pol 1ution Control
 Standards of  Performance
 Volatile Organic  Compounds
 Magnetic Tape
 Ueb Coating
  Air Pollution Control
   13B
3. DISTRIBUTION STATEMENT
Unlimited
19. SECURITY CLASS IThis Report)
 Unclassified
I 21. NO. OF PAGES
I  94
                                              20 SECURITY CLASS (This page;
                                               Unclassified
                                                                         22. PRICE
EPA Form 2220-1 (R<.y. 4-77)
                      PREVIOUS EDITION IS OBSOLETE

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