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
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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,
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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
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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
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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.
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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,
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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.
1-11
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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
1-12
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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.
1-13
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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)
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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)
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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.
2-4
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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
2-5
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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
2-6
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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
2-7
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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
2-8
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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.
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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.
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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.
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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
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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.
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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
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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
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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.
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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.
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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
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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
2-28
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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,
2-46
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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
2-47
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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
2-48
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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.
2-49
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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
2-50
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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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e
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o
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200 —
150 —
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OU
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Inlet Concentration
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I
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Figure 2-6. Tenth adsorption cycle with hew carbon.
2,000
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Figure 2-7. Last adsorption cycle prior to carbon replacement.
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.
2-58
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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
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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
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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.
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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.
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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."
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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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