& EPA
          United States
          Environmental Protection
          Agency
             Office of Air Quality
             Planning and Standards
             Research Triangle Park, NC 27711
EPA-453/R-94-074b
November 1994
          Air
HAZARDOUS AIR POLLUTANT
EMISSIONS FROM MAGNETIC
TAPE MANUFACTURING
OPERATIONS
          Background
          Information for
          Promulgated
          Standards

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Hazardous Air Pollutant Emissions from Magnetic
  Tape Manufacturing Operations-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

                         November 1994

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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
Offices  (MD-35), u. S. Environmental  Protection Agency,  Research
Triangle Park,  N.C. 27711,  or from National Technical Information
Services, 5285 Port Royal Road, Springfield, Virginia 22161
                               11

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                 ENVIRONMENTAL PROTECTION AGENCY

                     Background Information
                            and Final
                 Environmental Impact Statement
              for Hazardous Air Pollutant Emissions
           From Magnetic Tape Manufacturing Operations
                          Prepared by:
                                                 int
                                                  (Date)
feruce C. xJordan               .  .  .
Director^,  Emission Standards Division
U. S. Environmental Protection Agency
Research Triangle Park, N.C.  27711

1   The promulgated standards of performance would reduce
  '  hazardous air pollutant emissions from existing and new
    magnetic tape manufacturing operations that are major sources
    of hazardous air pollutant emissions.  Under section 112 of
    the Clean Air Act as amended in 1990, EPA is authorized to
    require the maximum degree of reduction in emissions _ of
    hazardous air pollutants that is achievable, taking into
    consideration the cost of achieving such emission reductions,
    and any nonair quality health and environmental impacts and
    energy requirements.

2   Copies of this document have been sent to the following
    Federal Departments:  Labor,_Health and Human Services
    Defense, Transportation, Agriculture, Commerce, Interior, and
    Enerqy; the National Science Foundation; the Council on
    Environmental Quality; members of the State.and_Territorial
    Air Pollution Program Administrators; the Association of
    Local Air Pollution Control Offices; EPA Regional
    Administrators; and other interested parties.

4.   For additional information  contact:

    Ms. Gail Lacy
     Coatings and Consumer Products Group  (MD-13)
     U.  S. Environmental Protection Agency
     Research Triangle Park,  N.C.  27711
     Telephone:   (919)  541-5261

 5.   Copies  of  this document may be obtained from:

     U.  S. EPA  Library (MD-35)
     Research Triangle Park,  N.C.   27711

     National Technical Information Service
     5258  Port  Royal  Road
     Springfield,  VA 22161
                                111

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IV

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                        TABLE OF CONTENTS
LIST OF TABLES
1.0  SUMMARY  .  .  .  ............ .  ..... •      1-1
     1.1   SUMMARY OF CHANGES SINCE PROPOSAL  ......      1-1
     1 . 2   SUMMARY OF IMPACTS OF PROMULGATED ACTION ...      1-2

2.0  SUMMARY OF PUBLIC COMMENTS ........  .....      2-1
     2.1   SELECTION OF EMISSION POINTS .........      2-1
     2.2   SELECTION OF AFFECTED SOURCES   ..... ...      2-4
     2.3   APPLICABILITY OF THE STANDARD   . .  ......      2-6
           2.3.1  Low HAP Usage Exemption  ........      2-6
           2.3.2  Definition of Potential to Emit  ....     2-14
           2.3.3  Regulation of Nonmagnetic Tape
                  Operations and Inclusion of Leader Tape
                  in the Source Category   ........     2-15
           2.3.4  Regulation of Research and
                  Laboratory Operations .........     2-17
     2.4   DESCRIPTION OF EMISSION CONTROL TECHNOLOGY  . .     2-21
     2.5   IMPACTS OF THE PROPOSED STANDARD .......     2-24
     2 . 6   SELECTION OF MAXIMUM ACHIEVABLE CONTROL
           TECHNOLOGY  (MACT)   .........  .....     2-26
           2.6.1  Selection of the MACT Floor ......     2-26
           2.6.2  Selection of MACT ...........     2-29
     2.7   SELECTION OF COMPLIANCE DATES   ........     2-32
     2.8   SELECTION OF EMISSION LIMITS AND EQUIPMENT/
           WORK PRACTICE SPECIFICATIONS .........     2-37
           2.8.1-  Periods when the Coater  is Down  ....     2-37
           2.8.2  Standard for Particulate Transfer ...     2-42
           2.8.3  Requirements for Wastewater ......     2-46
           2.8.4  Miscellaneous .  . ...........     2-49
     2 . 9   SELECTION OF TEST METHODS AND
           MONITORING REQUIREMENTS  ...........     2-51
           2.9.1  Site -specific Operating  Parameters   . .     2-5,1
           2.9.2  Test Methods  .............     2-53
           2.9.3  Compliance and Monitoring ........     2-54
           2.9.4  Miscellaneous ...........  . .    2-57
     2.10  SELECTION OF REPORTING AND RECORDKEEPING
           REQUIREMENTS .................    2-62
     2.11  INTERACTION OF THE MAGNETIC TAPE NESHAP WITH
           THE GENERAL PROVISIONS  ............    2-65
     2 . 12  OVERLAP OF MAGNETIC TAPE NESHAP WITH OTHER
           STANDARDS AND SOURCE CATEGORIES  .......    2-67
     2.13  WORDING OF THE STANDARD  ...........    2-70
     2.14  MISCELLANEOUS  ......... .......    2-76
           2.14.1 Alternative  Compliance Plans   .....    2-76
           2.14.2 Other Miscellaneous Issues  ......    2-84
     2.15  PERFORMANCE SPECIFICATIONS  .  .  ........    2-88
           2.15.1 Performance  Specification 8 ......    2-88
           2.15.2 Performance  Specification 9 ......    2-97

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                          LIST OF TABLES

                                                              Page
TABLE 2-1.   LIST OF COMMENTERS ON NATIONAL EMISSION
             STANDARDS FOR HAZARDOUS AIR POLLUTANTS
             FROM MAGNETIC TAPE MANUFACTURING
             OPERATIONS	      2-2

TABLE 2-2.   LIST OF ALL PS 101 COMMENTERS	     2-89

TABLE 2-3.   LIST OF ALL PS 102 COMMEKTERS	     2-89
                                VI

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                       .1.0  SUMMARY

1.1  SUMMARY OF CHANGES SINCE PROPOSAL
     In response to public comments and as a result of additional
evaluation by U. S. Environmental Protection Agency (EPA),
changes have been made to the proposed standards.  Significant
changes are summarized below, and are explained fully in the
response to comments.
     1.  The rule does not apply to research and laboratory
facilities, or to a coating line in which magnetic tape
production is 1 percent or less of total production from that
line in terms of square footage coated in any 12-month period.
     2.  Leader tape production is not included  as part of
magnetic tape manufacturing operations.
     3.  The rule does not apply when nonmagnetic  tape products
are manufactured on affected sources.
     4.  The applicability and intent of  the hazardous air
pollutant  (HAP) usage  limits have  been clarified in  §  63.703(b).
     5.  The final rule .[§ 63.703 (c) (4)3  allows  owners or
operators  of affected  sources the  option  of controlling  coating
operations more stringently  in lieu  of controlling HAP emissions
from solvent  storage  tanks.
     6.  The  final rule  includes an  alternative  standard to
control  HAP from particulate transfer;  it requires venting
particulate HAP to a  baghouse or fabric  filter that  exhibits no
visible  emissions when controlling particulate HAP transfer
 operations.
      7.   The final rule requires the same fraction removed for
 HAP compounds in wastewater from magnetic tape manufacturing
 operations as is required in Table 9 of 40 CFR Part 63,  Subpart G
                                1-1

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 of the national emission standards for organic hazardous air
 pollutants from the synthetic organic chemical manufacturing
 industry.  Any control technique may be used to meet the
 treatment requirements.  Also, monthly monitornig of the
 wastewater concentration is allowed to demonstrate continuous
 compliance.
      8.  The compliance time for existing affected sources has
 been changed to 2 years after the effective date, unless a new
 control device is needed to comply with § 63.703(c)  or (g).   If a
 new control device is needed,  an owner or operator of an existing
 affected source must comply within 3 years of the effective date.
      9.  The final rule allows an owner or operator to use a
 magnetic tape coating that contains no greater than
 0.18  kilograms (kg)  of HAP per liter (L)  of coating solids for a
 coating operation,  in lieu of  meeting the 95 percent overall HAP
 control efficiency for that coating operation.
      10.   The final  rule [§§ 63.703(i)  and 63.704 (b) (11) (ii)]
 contains  procedures  for establishing an alternate HAP
 concentration limit  to demonstrate compliance with the  standards
 when  coating  operations are not  occurring.
      11.   The material balance averaging time was changed  in the
 final rule.   The  averaging  time  is now 7  days to  determine
 compliance with the  standard.
      12.   The definition of affected  source  was changed from each
 coating line,  piece  of mix  equipment,  storage tank,  etc., to  the
 entire  magnetic tape manufacturing operation.
 1.2   SUMMARY  OF IMPACTS OF  PROMULGATED ACTION
      The  environmental and  energy  impacts for this rule were not
 affected  by changes made to the  rule between proposal and
 promulgation.
      Several  commenters' provided comments on the  estimate of
 nationwide compliance  costs  for the standard.  The EPA did revise
 facility-specific cost  impacts between proposal and promulgation
based on  information received from one facility.  The revised
 industrywide annual costs to comply with the standards are
$822,000/year  (yr).  This cost includes the annual cost of
                               1-2

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control ($596,120), annual compliance costs including initial
performance tests and ongoing monitoring ($115,640/yr),  and
annual reporting and recordkeeping costs ($110,240/yr).   The
total industrywide capital investment is estimated to be
$5,206,920.  The associated cost effectiveness is $390/megagram
(Mg)  ($354/ton) HAP controlled.  The costs for new sources are
unchanged from proposal.
     The economic impacts of this rule were recalculated to
reflect a revision in the estimated industrywide annual costs
associated with this rule.  Despite the cost revisions,  the
conclusion of the economic impact analysis remains the same.  The
economic impacts of this rule are not considered to be
significant.  Under this rule, the average price of magnetic tape
products would only need to increase by 0.03 percent  in order for
the magnetic tape industry to fully recover the new annualized
costs.
                                1-3

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                 2.0  SUMMARY OF PUBLIC COMMENTS

     A total of 17 letters commenting on the proposed standard
and the background information document (BID) for the proposed
standard were received.  A list of commenters,  their
affiliations, and the EPA docket number assigned to their
correspondence are given in Table 2-1  .
     For the purpose of orderly presentation, the comments have
been categorized under the following topics:
      1.  Selection of Emission Points;
      2.  Selection of Definition of Affected Sources;
      3.  Applicability of the Standard;
      4.  Description  of Emission Control Technology;
      5.  Impacts of the Proposed Standard;
      6.  Selection of Maximum Achievable Control Technology
 (MACT);
      7.  Selection of Compliance Dates;
       8.  Selection of Emission  Limits or Equipment/Work Practice
 Specifications;               '    ,
       9.  Selection of Test  Methods  and Monitoring  Requirements;
      10.  Selection of Reporting and Recordkeeping  Requirements;
      11.  Interaction of  Magnetic Tape National Emission
 Standards for Hazardous Air  Pollutants (NESHAP)  with the General
 Provisions;
      12.  Overlap of  NESHAP  with Other Standards and Source
 Categories;
      13.  Wording of  the Standard;
      14.  Miscellaneous;  and
      15.   Performance Specifications.
                                2-1

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 TABLE 2-1.  LIST OF COMMENTERS ON NATIONAL EMISSION STANDARDS
          FOR HAZARDOUS AIR POLLUTANTS FROM MAGNETIC
 ,	TAPE MANUFACTURING OPERATIONS
  Docket item
  No.a         Coitimenter and affiliation
  IV-D-01      P.  Gerbec,  Minnesota Pollution Control Agency
  IV-D-02      B.R.  Stephens,  Tennessee Department of
               Environment & Conservation,  Division of Air
               Pollution Control
  IV-D-03      R.J.  Connor,  Manufacturers of Emission
               Controls Association
  IV-D-04      J.E.  Tacconi  and G.D.  Garner, 3M Environmental
               Engineering and Pollution Control
  IV-D-05      J.W.  Walton,  Tennessee Department of
               Environment & Conservation,  Division of Air
               Pollution and Control
  IV-D-06      M.  Farmer,  Sony Magnetic Products,  Inc.  of
               America
  IV-D-7       R.H.  Colby  and  D.F.  Theiler,  State Territorial
               Air Pollution Program  Administrators
  IV-D-8       M.J.  Wax,  Institute  of Clean Air Companies
  IV-D-9       M.  Feldstein, Bay Area Air Quality Management
               District
  IV-D-10      D.  Driesen, Natural  Resources Defense Council
  IV-D-11      w.  0'Sullivan,  State of New  Jersey,  Department
               of  Environmental Protection  and  Energy
  IV-D-12      K.W.  Holt,  Department  of Health  & Human
               Services
  IV-D-13      L.  Lizewski,  Eastman Kodak Company
  IV-D-14      C.  Rainey and A.  Johnson,  Graham Magnetics
  IV-D-15      R.  Wood, State  of Nebraska, Department of
               Environmental Quality
  IV-D-16      Dave  Hild, Anacomp
  IV-D-17      J.  Udo,  Fuji
  IV-F-1       Transcript of Public Hearing  on  Proposed
               NESHAP  from Magnetic Operations.  Speakers
               were:   Mr. David  Carlson, Anacomp;
  	Ms. Janice Tacconi,  3M
a
 •The docket number for this project is A-91-31.  Dockets are
 on file at EPA Headquarters in Washington, DC.
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2.1  SELECTION OF EMISSION POINTS
     Comment;   One commenter (IV-D-6)  stated that condensate from
the carbon adsorption system should not be considered a
wastewater stream.  At the commenter's facility this stream is
routed to a stripper, which, the commenter contends, is a solvent
purification process, not wastewater treatment.  The commenter
further stated that only the water stream exiting the solvent
purification stripping column should be considered wastewater,
and because volatilization of HAP from this stream is negligible,
this stream should not be considered an emission point.
     Response:  The commenter is correct in that the steam
stripper may be considered a purification process to remove
additional solvent from the water phase after a carbon adsorption
system is steam desorbed.  However, this interpretation of the
process does not  change the fact that the water phase from steam
desorption of the carbon adsorption system is a potential HAP
emission source.  If a steam stripper or some other treatment is
not used to remove solvent  from this water phase volatile HAP
solvents could be emitted to the air.  In addition, discharge of
this untreated water to a publicly owned treatment works  (POTW)
is a potential waterborne HAP emission source.  Despite the
magnitude of potential HAP  emissions from this wastewater,
controls must be  identified for all emission sources.  Based on
EPA's data, of the three  existing major sources  that use  steam to
desorb their  carbon  beds, all three treat the  resultant water
with a steam  stripper.  That part of the MACT  floor addressing
this emission point  was therefore selected as  treatment with a
steam stripper or alternate device that achieves  the same control
level.
     Comment;  One  commenter  (IV-D-9)  suggested  that standards be
included for  new and existing sources  to  limit HAP  emissions from
cleaning mix  equipment  such as  mixing  vats, mills,  and tote
tanks.   The commenter stated  that  emissions  resulting  from
cleaning of mix  equipment can be substantial  if  left
uncontrolled.  The  commenter  also  noted that  coating operations,
including magnetic  tape facilities  in the Bay Area Air Quality
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 Management District (BAAQMD),  are subject to regulations that
 require control of equipment cleanup operations.  Four strategies
 suggested by BAAQMD are not allowing the use of HAP in cleaning
 operations, operating a closed cleaning system, capture and
 control with an overall efficiency of at least 80 percent,  and
 establishing a solvent usage limit.
      Response:  The EPA conducted a survey of the magnetic tape
 industry,  including sources in the BAAQMD,  to determine emissions
 from cleaning and the level of control of these emissions being
 achieved.   One operation of concern was mix tank cleaning.   The
 survey results indicated that  some sources  were performing closed
 top tank cleaning or "venting" tanks to control.  However,  closed
 top tank cleaning emissions were no  different than open top tank
 cleaning emissions.   Reports of efficiencies associated with
 venting to control were not confirmed through capture  or control
 testing.   Based on the information collected,  that portion of the
 MACT floor addressing  this emission  point was determined to be no
 control for cleaning of mix tanks for new and existing sources.
 The EPA evaluated controls more stringent than the floor,  but
 believed the cost effectiveness to be unreasonable,  exceeding
 $14,500/Mg HAP ($13,100/ton HAP).
 2.2  SELECTION OF AFFECTED SOURCES
      Comment:   One commenter (IV-D-11)  agreed with the proposed
 definition of  "affected sources,"  stating that the definition is
 enforceable and that defining  emission points  as sources  is
 appropriate for the magnetic tape  industry.   However,  three
 commenters (IV-F-1 Tacconi and IV-D-4,  IV-D-14,  IV-D-16)  stated
 that  the definition of  affected source  is too  narrow,  and does
 not allow  facilities flexibility in  controlling  HAP  emissions.
 One commenter  (IV-F-1 Tacconi)   argued that the standard does  not
 consider prioritization of resources  to control  the  highest
 emitting sources  and will  force  capital  expenditures to bring
 low-emitting sources into  compliance, while preventing
 cost-effective  improvements  on higher emitting sources that could
have larger emission reductions.  This  commenter noted that a
broader definition of "affected source" would provide flexibility
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by allowing emissions averaging to determine the most
cost-effective method of control;  thus,  emissions averaging
should be allowed as an alternative to meeting the requirements
for each source.
     .This same commenter (IV-F-1 Tacconi, IV-D-4) claimed during
the public hearing and in written comments that the narrow
definition of "affected source" would conflict with the
requirements of the General Provisions.  For example, the General
Provisions require a startup, shutdown, and malfunction plan for
each affected source.  The commenters argued that this would be a
significant burden, and that instead a single startup, shutdown,
and malfunction plan should be required for the entire facility.
     The second commenter  (IV-D-14) recommended allowing the
definition of an affected source to include an enclosed area in
which one or several common and integrated processes occur.  For
example, all equipment in a mix or coating room  should be defined
as a single affected source, and fugitive emissions  from solvent
recovery should be a single affected source.  From the proposed
definition it is unclear whether each piece of mix equipment or
emissions from each piece of equipment is required to be vented
to a control device.  The commenter suggested that EPA allow
capture and control of emissions from mix preparation equipment
or mix preparation rooms as well as emissions from wash sinks  or
the mix preparation rooms  in which the wash sinks are located.
The  commenter maintained that  it is economically easier to vent
the  entire room than each piece of equipment, which  would be
                                                 ,••
redundant and unnecessarily  costly. .
     The  third  commenter  (IV-D-16) stated that  the definition  of
affected  source is  overly  restrictive.   The commenter recommended
that enclosed mix rooms be  considered  a  single  process unit and a
single  affected source, stating that a broader  definition  of
affected  source would  provide  flexibility and allow  emissions
averaging.   The commenter  argued  that  under this approach
environmental protection will  be  equal to  if  not greater  than
with the  narrower definition and  domestic producers  would  not  be
 further disadvantaged by  the burden  of regulatory costs.
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      Response;   The  EPA has  determined that  a  broader  definition
 of  affected  source is  reasonable.   The definition  of affected
 source has been  changed to encompass  the  entire magnetic  tape
 manufacturing facility.   The EPA agrees with the majority of
 commenters that  a broader definition  of affected source would
 increase  flexibility not only for  owners  or  operators  of  magnetic
 tape  manufacturing operations but  for States implementing the
 rule  under Section 112  (1) of the  Act as  well.  Comments
 regarding prioritization of  emission  points  and the opportunity
 for emissions averaging are  addressed in  Section 2.14.
      The  EPA also agrees that changing the definition  to  the
 entire facility  will make the applicability  of the General
 Provisions less  confusing, and will require  clarification of
 fewer sections of the General Provisions  in  Subpart EE.   For
 example,  as  noted by one commenter, under the  original definition
 of  affected  source,  the  General  Provisions could have been
 interpreted  as requiring a startup, shutdown and malfunction plan
 for each  wash sink,  storage  tank,  etc., although that was not the
 intent.
      Two  commenters  (IV-D-14,  IV-D-16)  requested that several
 emission  sources for example,  mix  equipment  and coating
 operations,  be defined as a  single source so that each piece of
 equipment would not have to  be ducted individually to a control
 device.   Both the proposed and final  rule do allow use of a total
 enclosure (around multiple emission sources) vented to a  control
 device as an alternative method  of compliance; a narrow source
 definition would not preclude  this practice.  Fo'r example, to
 comply with  either the proposed  or final  rule, an owner or
 operator  could control emissions from mix preparation equipment
by venting the mix room(s) to  a  control device.  This has been
made  clearer in the final rule.
2.3  APPLICABILITY OF THE STANDARD
2.3.1  Low HAP Usage Exemption
     Comment;  Seven commenters  (IV-D-1,  IV-D-4,  IV-D-7,  IV-D-9,
IV-D-13,  IV-D-14, IV-D-16) suggested  that EPA should clarify the
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intent of the HAP usage cutoff and modify the cutoff
requirements.
     Three commenters (IV-D-4, IV-D-14, IV-D-16) suggested
clarifying that § 63.701(a)(2) of the proposed rule, which
outlines the HAP usage cutoff, applies to magnetic tape
manufacturing operations located at a facility that is a major
source of HAP emissions and that area sources are exempt from the
standards.  Two commenters (IV-D-14, IV-D-16) stated that the
rule could be read to apply to all sources that utilize more than
10 tons per year  (tons/yr) of any one HAP or 25 tons/yr of any
combination of HAP, and that EPA must clarify that a
manufacturing operation will not be subject to the standard
unless it emits or has the potential to emit, considering
controls, more than 10 or 25 tons/yr of HAP.  The commenters
further stated that applying a MACT standard based on an
operation's usage of HAP and not on its emissions or potential
emissions, considering controls, exceeds the legal requirements
of the Clean Air Act  (the Act)          •   •
     One commenter  (IV-D-13)  recommended that EPA clarify the HAP
threshold exemption wording so that it  is supported by the
explanation in the preamble.  The commenter stated that in the
regulation the threshold appears to apply to the magnetic tape
manufacturing operation, not the entire facility, but it is
unclear in the preamble whether the Agency intended for this
threshold to be applied to the facility or the magnetic tape
manufacturing operation.
     Two commenters  (IV-D-1,  IV-D-7) found the use of the word
"utilize" in the HAP usage cutoff confusing  in  the context of
certain sources.  The commenters questioned whether it makes
sense to say that a wastewater treatment system "utilizes" a HAP.
Both commenters recommended defining the term  "utilize" for each
affected source to make the use of  the  term more meaningful.  One
commenter  (IV-D-9)  suggested  redefining the  term  "utilize" as the
net usage; that is, the inventory at the beginning  of a 12-month
period, plus any  additional amounts purchased during the year,
minus any amounts  shipped  offsite during the year, minus the
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 amount in inventory at the end of the 12-month period.  This
 would mean that the HAP usage cutoffs would be based on net
 usage, excluding HAP that is reused or resold.  The commenter
 believes this will encourage pollution prevention.
      Two commenters (IV-D-1, IV-D-7)  suggested that
 § 63,. 701 (a) (2)  of the proposed rule should state that the owner
 or operator shall use the annual HAP utilization report required
 by §§ 63.703(g)(1)  and (2)  of the proposed rule to  determine
 whether they are over or under the threshold for exemption.   Both
 commenters also believed that a discrete 12-month reporting
 period is  too long to wait to determine if a source has gone over
 the threshold.   They suggested a 12-month rolling total,  which
 would reduce the amount of time required to determine if  a source
 has exceeded the threshold.
      Two commenters (IV-D-4,  IV-D-13)  stated that potential  to
 emit is a  better basis for the threshold HAP cutoff than
 utilization.  One of these commenters  (IV-D-4)  suggested  that
 §  63.701(a)(3)  of the proposed rule be edited to include  the
 facilities'  potential  to emit in determining the applicability of
 the HAP usage cutoff.   The commenter suggested changing
 §  63.703(g)  of  the  proposed  rule which requires  an  annual  report
 of HAP utilization  to  include the consideration  of  potential to
 emit by alternatively  requiring owners or operators to report the
 quantity of  HAP  emitted to the atmosphere during a  12-month
 period.  The other  commenter suggested that EPA  change the
 wording from "quantity of HAP utilized"  to "quantity of HAP
 emitted" throughout  the regulation.  They argued' that  utilization
 ignores  actual emissions that may emanate  from a magnetic tape
 operation.  The  example used  in the preamble might  exceed a
 potential  to emit threshold  in a few days  per  year.   The
 assumption is made  that the example facility has  no control
 equipment,  no Federally enforceable limitations  on  the hours  of
 operation  or use of  control equipment  because, otherwise,
utilization and potential to  emit  should be equivalent.  The
 commenter also maintained that utilization penalizes facilities
 that have  installed  control devices (and now have potential  to
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emit less than 10 tons/yr of HAP),  yet exempts facilities that
emit less than 25 tons/yr of HAP.  If potential to emit is used,
magnetic tape coating operations can choose to become exempt from
the regulation by installing control devices or accepting
Federally enforceable permit conditions to limit their emissions
from magnetic tape operations to below the stated threshold.  The
commenter suggested adding language to consider potential to emit
in determining applicability of  the cutoff.  The commenter
alternatively suggested that EPA adopt some de minimis level of
HAP emissions, based on actual HAP emissions, to exempt  small
scale operations.
     Two commenters  (IV-D-1, IV-D-7)  suggested that
§  63.70l(a)(3) of the proposed rule,  which states  that facilities
that exceed the  threshold for at least 1  year must comply with
the proposed standards,  should be  reworded to make it  clear that
the owner  or operator must exceed  the thresholds  for 1 year prior
to these provisions  becoming effective.   The section as  proposed
could mean that  §§  63.701(a)(3)(i)  and (ii)  must  be  complied with
for 1 year.
      Two commenters  (IV-D-1,  IV-D-9)  suggested allowing  sources
 subject to the control requirements to use the HAP usage
 exemption in the future.  One commenter  (IV-D-1)  suggested that
 EPA consider exempting sources  that go below the HAP usage
 threshold for several years in  a row from at least monitoring and
 recordkeeping requirements.  The commenter reasoned that such an
 exemption  is reasonable because area sources were not determined
 to be a health  threat, and because these  sources'are likely to
 continue using  any control devices that  are  currently employed.
      Two commenters  (IV-D-1, IV-D-7) stated  that  the HAP usage
 cutoff appears  to exempt  each affected source that  falls below
 the HAP usage criteria  of 10 tons/yr of  a single  HAP  or
 25 tons/yr of total HAP.   Thus, each storage tank,  wash sink,
 etc. that  utilizes  HAP  in quantities below the threshold could  be
 exempted.   This section as written could exempt  a magnetic tape
 operation with  actual usage well  over the 10 tons/yr of a single
 HAP  or 25  tons/yr  of  any combination of  HAP threshold.   One
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 commenter  (IV-D-7) suggested changing the phrase "each affected
 source" to read  "each magnetic tape operation."
      Response:  The EPA agrees with the commenters that the
 proposed HAP usage cutoff requires clarification in the final
 rule.  The first clarification is that only magnetic tape
 manufacturing operations at major sources of HAP emissions are
 required to comply with Subpart EE.  However, the owner or
 operator of any stationary source with magnetic tape
 manufacturing may choose to be subject to the HAP usage limits in
 Subpart EE to obtain a Federally enforceable limit on the
 potential to emit HAP from magnetic tape manufacturing
 operations.  Essentially,  the HAP usage limits are a surrogate
 for the potential to emit HAP.   A reason the owner or operator
 may want to use this mechanism in Subpart EE is if the stationary
 source would be a major source,  unless it had the potential to
 emit limit established by this  subpart.   The owner or operator
 could use the potential to emit  established for magnetic  tape
 manufacturing operations (determined by the HAP usage limit),  in
 conjunction with the potential  to emit from the other HAP
 emission points at  the stationary source,  to be an  area source.
 Note that  the determination  of whether a  stationary source  is
 major or area is  dependent on the potential  emissions  from  all
 points  within the stationary source, or group of  stationary
 sources located within a contiguous area and under  common
 control.
      Subpart  EE does not preclude  the  determination of potential
 to emit, considering controls, by  other mechanisms.  For example,
 without controls, the potential to emit HAP  could be low because
 the  solvents used in coating are not HAP.  An operation that has
 emission controls may have its potential to emit established by a
 Federally enforceable State operating permit.  The definition of
 "federally enforceable" in the General Provisions, Subpart A of
Part 63, includes other examples of limits that are federally
enforceable.  The EPA did not include specific provisions in
Subpart EE to create enforceable limits for controls because, for
this source category, very detailed and complex provisions would
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be required.  The HAP usage limits, by comparison, are
straightforward to determine, record, and can be easily confirmed
by regulatory authorities.  Because of the availability of the
other mechanisms and the few plants in this source category, the
EPA decided to include in this subpart only the HAP usage limits.
     If a stationary source becomes an area source by subjecting
its magnetic tape manufacturing operations to the HAP usage
limits in Subpart EE, then the control requirements of Subpart EE
would not apply.  Furthermore, for purposes of Section 112 of the
CAA, it would not be a regulated area source that would be
required to have an operating permit under 40 CFR Part 70.  In
other words, being subject to the HAP usage limits in the rule
does not in and of itself make the facility subject to Part 70.
However, there may be other  reasons  that  the stationary source  is
required to comply with  Part 70.   For example,  it may be a major
source of emissions of volatile organic  compounds.
     The HAP usage limits  at magnetic tape manufacturing
operations  have been  changed from  their  proposed values of
10 tons/yr  of  an  individual  HAP and  25 tons/yr  of combined  HAP  to
take  into account the potential emissions from  other  emission
points at the  stationary source.   In the final  rule,  the  HAP
usage  limits  for  the  magnetic tape manufacturing operation  are  to
be the values  that,  when summed with the values of the potential
 to emit  each HAP  from emission points other than magnetic tape
manufacturing operations at the  stationary source,  are less than
 10 tons/yr  of an individual HAP  and 25  tons/yr of combined HAP.
      To  illustrate how the HAP usage limits woul'd be determined,
 three example situations have been developed.   The first example
 is a stationary source at which the only HAP emission points are
 in the magnetic tape manufacturing operations.   Since no other
 points go into the calculation in this case,  the limits would be
 less than 10 tons/yr of an  individual HAP and less than
 25 tons/yr of a combination of HAP.
      The second example is  a stationary  source at which the only
 HAP emission points are the magnetic tape operation and a boiler.
 Assume that the boiler, without controls, has the potential to
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 emit 1 ton/yr of HAP, and that the HAP from the boiler are
 different from those emitted from magnetic tape manufacturing.
 The limits on HAP usage in the magnetic tape manufacturing
 operation would be to not exceed 10 tons/yr for each individual
 HAP and 24 tons/yr for the combination of HAP (i.e., the
 25 tons/yr major source threshold minus the 1 ton/yr potential to
 emit of the boiler).
      The third example is a stationary source in which the HAP
 emission points,  except those associated with magnetic tape,  have
 controls with Federally enforceable emission limits, such as  a
 new source performance standard (NSPS)  under section 111 of the
 Act.  Assume that these federally enforceable limits have the
 effect of limiting the potential HAP emissions from these
 emission points to 4 tons/yr of a solvent that is also used in
 magnetic tape manufacturing (e.g.,  toluene).   The limit on the
 magnetic tape manufacturing HAP usage for toluene would be to not
 exceed 6 tons/yr,  for other individual  HAP to not exceed
 10 tons/yr,  and for  the combination of  HAP to not exceed
 21 tons/yr.
     Two commenters  remarked that a 12-month  period is  too long
 for determining if the  threshold had been exceeded;  the
 commenters  suggested a  12-month rolling total.   The EPA agrees;
 the final rule requires  that  the HAP usage be  calculated monthly.
     In  the  final  rule,  the  EPA has  removed the  proposed
 requirement  that after a source has  been  subject to  the control
 requirements  of the MACT standard,  the  owner or  operator can  not
 take advantage  of  the HAP usage limit anymore.   The  points made
 by the commenters who suggested this  change are  being considered
 as part of a  general policy on  the timing  aspects of limitations
 on potential  to emit, which is  beyond the  scope  of this
 rulemaking.   Therefore,  this rulemaking does not include any
 specific requirements of this nature.
     One commenter suggested that the HAP usage  cutoff be defined
 in terms of net usage to encourage onsite solvent recovery and
 reuse.   The EPA agrees that net usage encourages pollution
prevention by subtracting out the amount that is recycled at the
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facility.   Therefore,  the definition of "utilize"  has been
changed to incorporate this concept into the final rule by
allowing the owner or operator to determine utilization as the
HAP inventory for the magnetic tape manufacturing operation at
the beginning of a 12-month period plus the amount purchased
during the 12-month period minus the amount in inventory at the
end of the 12-month period.  However, the proposed definition is
also included as a choice, because owners or operators of a plant
that uses HAP for other purposes may not keep their inventory of
HAP bought for the magnetic tape manufacturing operations
separate.   Therefore, they may prefer a record based on the
amount of HAP actually put into the process.
     The proposed rule stated that when a source exceeded the HAP
usage limit, the owner or operator would be required to comply
with the control requirements of the rule by 1 year after the
exceedance; this time had been selected to be consistent with the
period given for existing sources to comply after the effective
date.  In the final rule, the EPA has clarified that the source
shall be required to comply with the control requirements for
major sources only if the owner or operator chooses to no longer
be subject to the HAP usage limits and, in doing so, becomes a
major source.  In such a case, the owner or operator would be
required to notify the Administrator or delegated State of this  .
intent.  The owner or operator would then have the same amount of
time to comply with the control requirements as would an existing
source, according to § 63.6(c)(5) of the General Provisions.  The
HAP usage limits would continue to apply until the control
requirements were met.
     An exceedance of a HAP usage limit would be a violation of
the HAP usage provisions of Subpart  EE.  If the source also has
exceeded the major source  definition thresholds by exceeding the
HAP usage limit, and the  source does not have an operating permit
for major sources under 40 CFR Part  70, the source potentially
could be found  in violation of the requirements of Part  70 as
well.
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      Another clarifying change in the rule is that the owner or
 operator is not required to include 12 months of HAP usage data
 in the initial notification report required by the General
 Provisions; this requirement would have required sources  to keep
 records before the effective date of the rule.   Instead,  the
 owner or operator is required to submit the values of the limits
 on the amount of HAP utilized,  as determined in § 63.703(b)(2),
 along with supporting calculations,  with the initial
 notification.
      As in the proposed rule,  the owner or operator would be
 required to submit an annual report on HAP usage,  with the first
 one covering the 12-month period before the compliance, date of
 the rule (which,  in the final  rule,  would be 2  years after the
 effective date,  instead of the  proposed 1 year).   Because the
 final HAP usage limits are calculated monthly on a rolling
 12-month basis,  the final rule  would require a  report  within
 30 days of any exceedance of a  HAP usage limit.   It would be
 unreasonable to allow the owner or operator to  wait until the
 annual report  to report an exceedance.
 2.3.2  Definition of Potential  to Emit                ;
      Comment:   One commenter (IV-D-9)  recommended that EPA
 consider State and/or locally mandated controls  in the
 determination  of potential to emit.   The commenter urges  EPA to
 provide a simple mechanism for  such requirements  to be made
 Federally enforceable without requiring a new permit review.  The
 commenter argued that re-permitting  sources  that  hold  and comply
 with  State and local air permits  is  a waste  of  resources  and
 provides  no additional  environmental  benefits.
      Response;   A determination of a  source's potential to emit,
 as  defined in  40  CFR Part 63.2  of  Subpart A,  can  account  for air
 pollution control  equipment  as  well as  other limitations,  if  they
 are Federally  enforceable.   In  the definition of  Federally
 enforceable that  is  contained in Subpart A,  examples of Federally
 enforceable conditions  and limitations  are .listed.   These
 include,  among other things, limitations and conditions that  are
part  of an  approved  State  implementation plans  (SIP) and
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limitations and conditions that are part of an operating permit
issued pursuant to a program approved by EPA in a SIP as meeting
the EPA's minimum criteria for Federal enforceability.   Thus,
some State or locally mandated controls (i.e., those that are
federally enforceable) can be considered in the determination of
potential to emit.  It is, however, beyond the scope of this
rulemaking to determine which State programs meet the
requirements for federal enforceability and which do not.  The
only mechanism for limiting potential to emit that is specific  to
this subpart involves the HAP usage limits of §  63.703(b) and
 (h), as  discussed in  the previous  response.
2.3.3  p^nation o*  wnnmacmetip Tape Operations and Inclusion of
       •Leader Tape  in t--he Sour<-g Category
     Comment:  Two  commenters  (IV-D-4,  IV-D-13)  suggested
deleting §  63.70KO  of  the  proposed  rule, which requires
 compliance during  the manufacture  of  nonmagnetic tape  for any
 affected source  that  also is used  in  magnetic tape manufacture.
 The first commenter (IV-D-4)  cited the following reasons:
      1.   Additional controls may be necessary;
      2   Solvent recovery systems  of  magnetic and nonmagnetic
 tape processes are not necessarily compatible since different HAP
 may be used during production of magnetic and nonmagnetic
 products, resulting in the need for additional solvent recovery  .
 equipment and the associated costs to recover solvent from
 nonmagnetic tape processes;
       3.  Nonmagnetic tape would be expected to be covered by  the
 future  MACT standards for the  "paper and other  webs" source
 category, due to be  promulgated in the year 2000, and there may
 be conflicting  requirements;
       4.  The nonmagnetic tape  process was not considered in
 developing  the  MACT  floor or  the  environmental  and  cost impacts
 associated with the  standard;  and
       5.  The  standard probably exceeds  the MACT floor for
 nonmagnetic tape manufacturing.
       The second commenter (IV-D-13),  like the first commenter,
  stated that inclusion of nonmagnetic products in this rule
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 overlaps the paper and other webs source category, which they
 claim was not the intent of Congress.  The commenter repeated the
 assertion that EPA has not identified the MACT floor for this
 source category for HAP used in nonmagnetic product
 manufacturing.  The commenter stated that a facility would be
 favored in the regulation if it manufactures nonmagnetic products
 and has more than one line because it would not be subject to the
 regulation.
      Commenter IV-D-04 also suggested deleting the phrase "and
 leader tape" from the definition of magnetic tape manufacturing
 operation for the same reasons described above for nonmagnetic
 tape manufacturing.
      Response:   For nonmagnetic tape manufacture,  the limited
 information the EPA had at the time of proposal led the EPA to
 believe that magnetic tape coating and nonmagnetic tape coating
 done on the same line 'would use solvents that  could be  controlled
 using a common device.  Upon review of the  comments,  the EPA
 recognizes  the  potential  use of different solvents that are
 incompatible with respect to a solvent recovery device.   Given
 this situation,  and  the  fact that  manufacturing of nonmagnetic
 tape products would  be covered by  the source category for paper
 and other web coatings,  the  EPA decided  not to  require  affected
 sources  to be subject  to  Subpart EE  during the  coating  of
 nonmagnetic  tape products.
      Upon consideration of the  comments  on the  inclusion of
 leader tape,  the EPA agrees  that it  did not adequately  factor
 leader tape  into the analysis of the  floor for  the magnetic tape
 manufacturing source category.  The  EPA examined only a  situation
 where leader  tape and  magnetic tape were manufactured on the same
 line.  The comments brought to our attention that leader tape
 manufacture is not necessarily as similar to magnetic tape
manufacture as originally anticipated.  For example, some leader
 tape manufacture uses  solvents that are incompatible with those
used for magnetic tape.  Leader tape also would be covered by the
paper and other webs source category.  Consequently, the EPA has
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decided not to include leader tape as part of the magnetic tape
manufacturing source category.
234  T?P.giilatinn of Research and Laborai-or-y Operations
     Comment:  Four commenters  (IV-D-4,  IV-D-13, IV-D-14,
IV-D-16)  stated  that research and laboratory activities  should be
exempt from the  standard,  regardless  of  whether they are
collocated at a  production facility,  and suggested  removing  the
phrase  "that are not collocated with  production coating  lines"
from §  63.701(b) of  the  proposed rule.
      The  first  commenter (IV-D-4)  cited Section 112(c)(7)  of the
Act,  which states  that EPA is  directed to "...establish a
 separate  category  covering research or laboratory facilities as
 necessary to assure equitable treatment of such facilities."
 This commenter and two others  (IV-D-14,  IV-D-16) believe that
 traditional controls cannot reasonably be applied to research
 facilities because of the wide variety and small amounts of
 materials that are used, the batch nature of research operations,
 and the different methods of research operations.  The  commenters
 also believe that it would be  impractical for  EPA to attempt  to
 construct an exemption  for each type of affected source within a
 research  operation, because it would be too complicated and
 time-consuming  for EPA.   Commenters also noted that  requiring
 collocated research and laboratory facilities  to use production  .
 control  equipment dramatically reduces  the amount  of research
 that can be conducted and impacts  competition.
      The second commenter (IV-D-13)  agreed, adding that the
 technical and  economic  feasibility of  controlling  research  and
 laboratory  lines  is dependent  on a variety  of  factors,  including
 the length  of" duct  work required to  route emissions to a control
 device,  safety and cross-contamination concerns regarding mixing
 emissions,  the flow rate and concentration  of  HAP from the
 research and laboratory facility relative to the capacity of the
  existing control  device,  and the schedule of operation at the
  research and laboratory facility.   Another commenter (IV-D-16)
:'  remarked that the capital costs of regulating collocated research
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  activities were not  considered in the  industry-wide  costs  of
  compliance.
      Two  commenters  (IV-D-1,  IV-D-4) suggested  that  a definition
  of  "collocated" be added to  §  63.701(b) of the  proposed rule.
  The section states that the  subpart does not apply to research or
  laboratory facilities that are  not collocated with production
  coating lines.  These commenters noted that "collocated" could be
  interpreted to mean  "in the  same room" or as "part of the same
  line," and recommended the rewording the section to state "at the
  same stationary source" or "on  contiguous property and under the
  same control" or other more specific language.
      Three commenters (IV-D-04, IV-D-14,  IV-D-16)  responded to
 EPA's request for information on the definition of de minimis
 manufacture of products for commercial sale from a research and
 development coating line.
      One commenter (IV-D-4)  recommended that  the standard adopt
 the definition of  research or laboratory  facility as  proposed by
 EPA.   The  commenter advised that EPA not  try  to further  define de
 minimis, for  example, either as a percentage  of materials  used or
 hours  of operation,  because  de minimis  may  vary by the 'nature of
 product being  produced (which would affect  the  amount of  coated
 material required  for each production unit) or  the concurrent
 level  of research  activities  (which would affect any  limitation
 based  on percentage  or hours  of operation).
     Two commenters  (IV-D-14,  IV-D-16)  suggested defining  the  de
 minimis  sale of products produced  at research and  laboratory
 facilities according  to the percent of  time the  'facility'is used
 for commercial activities.  The  commenters both  suggested
 defining de minimis manufacture  of products for  commercial sale
 in commerce as a magnetic tape manufacturing process that is not
 engaged in the manufacture of products for commercial sale in
 commerce for more than 50 percent of its total available
operating time.  One  commenter  (IV-D-14) included a maximum
aggregate HAP emission level in the definition of de minimis such
that no more than 5 tons per year of any one HAP or 10 tons
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per year of any combination of HAP would be emitted as result of
research and laboratory purposes.
     Response:  The EPA had proposed regulation of research and
laboratory facilities collocated with production lines, meaning
those research and laboratory facilities that were located at the
same major source site as the production lines.  The EPA believed
that the primary control device used to control HAP emissions
from coating operations may also be able to be used to control
HAP emissions from the research  facilities.  The EPA agrees that
in order to regulate research facilities at magnetic tape
manufacturing plants, a separate source category would need to  be
developed as directed by Section 112(c)(7) of  the.Act  to assure
equitable treatment of such facilities.  Furthermore,  based on
information received at proposal,  the  EPA  also agrees  that many
of the  types  of  emission points  at research  facilities (such  as
laboratory bench-scale equipment)  may  not  be able  to  be
controlled using the same  pieces of control  equipment as are  used
on manufacturing lines.   In addition,  research lines  are more apt
to operate  in batch mode  and  with many different  solvents  than
are  used in production.   This latter problem is  of specific
 concern when.a solvent  recovery device is  used,  because  the
 solvent recovery device (and associated distillation operations)
 are designed for recovery of  specific  solvents.   Therefore,  in
 the final rule,  research and laboratory facilities collocated
 with production lines are not regulated.
      In the final rule,  the definition of research or laboratory
 facility remains unchanged from the proposed definition,  which is
 identical to the definition in Section 112(c)(7)  of the Act.  The
 EPA disagrees with the two commenters who suggested that the
 phrase in the definition of research or laboratory facility  "not
 engaged in the manufacture of products for  commercial sale in
 commerce, except in a de minimis  manner" be interpreted as not
 engaged in commercial manufacture for more  than 50 percent of  its
 operating time.  The EPA does not believe that this  is a
 reasonable interpretation of  "de  minimis manner."  Otherwise,  the
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 Agency did not receive sufficient information that "de minimis
 manner" could be defined for this source category.    ;
      In its deliberation about the definition of research or
 laboratory facility for this source category,  the Agency
 evaluated the types of activities it considers to fit the
 definition in the Act.  Research and laboratory activities
 include those activities that are employed to develop a new
 coating,  substrate,  or end product,  ar well as activities devoted
 to optimizing the manufacture of a new material.   For example,  a
 magnetic  tape facility may have bench-scale research operations
 directed  to developing new coatings.   Once a promising' coating is
 developed,  the research activity may move to a laboratory-scale
 or pilot  plant coating line to determine if it can be properly
 applied,  dried,  etc.   Some marketing may take  place at this stage
 to determine if a market would exist for the product.   For
 example,  is there a  demand for this  type of product?   Can it meet
 the customer's specifications?  If the facility wishes to further
 pursue  the  coating,  it may be moved  to a line  that is  the same  as
 a  production line to  determine how the coating could  be
 manufactured on a full-scale basis.   The EPA believes  that all  of
 these activities are  research because their intention  is  to
 develop new products  or processes.
     Once a facility  determines that  the manufacture  of this
 product is  viable, however,  the EPA believes that  additional
 activities  are likely to be  beyond the research phase.  For
 example,  the  adjustment  and  optimization of a  process  that  is
 already operating on  a production  line should  not  be considered
 research.   Likewise,  if  a product  is  being manufactured and
 introduced  in a  retail environment, even on a  limited basis, the
 product is  likely to  be  fully developed.  It could be argued that
 research  is continuing even beyond this  point  in that the
 facility  is testing to determine the  correct market segment,
price,   advertising, etc.  The  EPA believes, however, that this
 type of "research" is beyond what was  intended by  the Act.  The
 company is obviously planning  eventual full-scale production; the
development of the new product and process is over.    \
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2 4  DESCRIPTION OF EMISSION CONTROL TECHNOLOGY
     Consent:  Two commenters (IV-D-3,  IV-D-8)  were generally
supportive of the proposed rule and noted that control devices
are available to control emissions to the level required by the
proposed rule.  The first con-neater  (IV-D-3) agreed with the EPA
that it is appropriate to have an emission format that is      _
technology neutral.  He further pointed out the use of catalytic
oxidation as  a possible control method for HAP.  The  commenter
claims that  a properly designed catalytic oxidizer will Wily
achieve 98 to 99 percent destruction efficiency which will
achieve the  emission  limits  in the  standard when coupled with-a
high efficiency vapor collection  system.  The  second  commenter
 (IV-D-8)  noted  that control  equipment  is  currently available for
 new and  retrofit  operations  that  can meet the  95 percent  control
 requirements of the proposed rule for  solvent  storage tanks, mix
 preparation equipment,  coating operations,  waste handling
 devices,  condenser vents,  and flushing of fixed lines.   The
 commenter further stated that overall control efficiencies of
 98 percent and greater can be achieved in some cases.
      Response:  The EPA appreciates the support of the proposed
 regulation and agrees that there are many different  control
 techniques  that could meet the requirements of Subpart EE.  For
 this reason, Subpart EE does not mandate a specific  type of
 control  requirement, but  instead specifies that a percent
 efficiency  be  achieved.   Control techniques other  than those
 presented  in the  final rule  can  be used  to comply  with the
 standards  as long as the  technique is demonstrated to meet the
 emission limitation in accordance  with  the test methods  and
 procedures of  §  63.7 of  Subpart  A and §  63.705  of Subpart  EE.  If
  the control technique used to comply with Subpart EE is  not
  included in § 63.704 (compliance and monitoring requirements),
  the owner or operator of the affected source will have to propose
  compliance monitoring for approval by the Administrator in
  accordance with  § 63.704(f).
       Comment:  Two commenters (IV-D-4, IV-D-16 and  IV-F-1
  Carlson) requested that EPA include specific provisions for  the
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  use of biofiltration as a control technology in the proposed
  rule.   In public hearing testimony,  commenter IV-F-l (Carlson)
  recommended that EPA consider biofiltration as a control
  technology.   The commenter stated that  biofiltration may
  potentially represent a superior  abatement  technology, yielding
  higher efficiency and reliability, and  lower costs.  This
  technology has been  used successfully in Europe  and Japan to
  treat  contaminated air and is  used extensively to treat natural
  gases  in  soil, decomposing solid  and liquid  organics in
  landfills, and treating organics  in wastewater.       ;
      The  same commenter in written comments  (IV-D-16) stated that
  the proposed rule should allow facilities the  opportunity to use
  innovative technologies.   Currently,  monitoring requirements and
  the requirement that a  source  request approval from' EPA to use an
  innovative technology make  it  extremely difficult for facilities
 to use innovative technology under the proposed rule. ^The
 commenter suggested that EPA allow flexible monitoring
 requirements for biofiltration including eddy diffusion,  open
 cell Fourier Transform Infrared (FTIR)  and flux chamber
 measurement techniques to determine average effluent  !
 concentrations in performance testing.   in addition, the
 commenter suggested  that EPA allow volumetric effluent flow  rate
 to be calculated from influent air flow  rate, and allow the  use
 of biofiltration with compliance demonstrated through monitoring
 of influent air  flow rate,  moisture levels,  and influent
 temperature,  which is consistent with provisions  made for
 monitoring temperatures to demonstrate compliance when using
 catalytic  incinerators and condensers.
      The other commenter (IV-D-4)  requested  that  EPA add language
 to the  standard to explicitly allow a facility  to submit a
 request to the Administrator that  would propose an alternate
 standard for a facility that has installed innovative control
 technologies, such as biofiltration, that may not be  capable of
meeting all the compliance  requirements of the  promulgated
standard.  The commenter stated that this strategy is necessary
to encourage introduction of new technologies that will have
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improved environmental and energy benefits compared to
traditional control strategies that are described in the proposed
standard.
     Response:   Neither the EPA's information at proposal nor the
comments received indicate any biofiltration units in place to
control HAP or volatile organic compound  (VOC) emissions from
magnetic tape manufacturing operations.  Furthermore, the
commenters did not provide specific information and data on
alternative testing or monitoring techniques for the EPA to
evaluate their ability to demonstrate the compliance status of
the source if biofiltration were used.  Because biofiltration is
still a new technology, extensive research and information
gathering would be necessary for the EPA to develop appropriate
testing and monitoring; this could not be accomplished without
delaying promulgation of the final rule.  Therefore, the EPA has
not included specific testing and monitoring provisions for
biofiltration units in the final rule.
     Section 63.704 (f) of the final rule  allows owners or
operators of affected sources to submit compliance monitoring
provisions for alternate control technologies to the
Administrator for  approval.  The EPA believes that an owner or
operator of an affected source that is exploring the use of
biofiltration or another innovative method as a control technique
will be more informed and better able  to  propose appropriate
testing  and monitoring.  As discussed  in  Section 2.7  of this
document,  the compliance timeframe for existing sources that must
                                                .-
install  a  control  device to comply with § 63.703(c)  or  (g) of
Subpart  EE is 3 years  from the effective  date of the standard  to
achieve  compliance.   The EPA  believes  that this extended
timeframe  will also allow owners or operators the  time  required
to propose alternative  testing and monitoring requirements.
      In  accordance with §§ 63.7 (c) (2)  and (f) of  Subpart A,  an
owner or operator  must  submit a  site-specific performance  test
plan at  least  60 days prior to the date by which  the performance
test must  be conducted.   In accordance with  § 63.7(c) (3),  the
Administrator will approve or disapprove  the plan (including
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alternate test methods) within 30 days of receipt of the plan; if
approval or disapproval is not received within this time and an
alternate test method had been proposed, the performance test
completion deadline will be changed to within 60 days after
receipt of approval.  Likewise, § 63.8 (f) of Subpart A outlines
similar procedures and timeframes for proposing and receiving
approval for alternative monitoring methods.
2.5  IMPACTS OF THE PROPOSED STANDARD
     Comment:  Three commenters  (IV-D-4, IV-D-14, IV-D-16 and
IV-F-1 Carlson) stated that they believe EPA has significantly
underestimated the cost of compliance with the standard for the
entire industry.  One commenter  (IV-D-4) believes that the actual
cost to industry will be 10 to 15 times EPA's estimate of the
cost of compliance  (the EPA's estimate at proposal was
approximately $2,200,000).  The commenter suggested that EPA
review all comments related to cost impacts from all facilities
and, if necessary, review the cost effectiveness of the proposed
rules and the cost impact on the industry.
     The second commenter  (IV-D-14) estimated that for three
facilities, costs would be $7.2 million.  The commenter stated
that EPA must reanalyze both the capital cost and annual
operating costs, and maintained that high capital costs and
operating costs raise the issue of achievability in the statutory
definition of MACT.
     The third commenter (IV-D-16 and IV-F-1 Carlson) believes
that EPA mischaracterized its facility's size and control
                                                s
technology requirements in estimating the cost of compliance.
According to the commenter, the cost of compliance represents two
to three times the profit budget for the magnetic tape industry
in fiscal year 1994.  The commenter believes the actual cost to
comply could be three to five times the EPA estimate.  The
commenter (IV-D-16) stated that the costs to install a carbon bed
adsorption system at their facility were underestimated by almost
$1.5 million,  chiefly because the size of production lines were
mischaracterized.  The commenter provided specific information on
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which to base their request to have the cost of compliance
increased for this facility.
     Response:  The EPA agrees with the third commenter (IV-D-16,
IV-F-1 Carlson) that compliance costs should be adjusted for the
facility that was mischaracterized•as small during development of
the compliance costs.  This commenter provided specific
information which supported their assertion that his facility was
mischaracterized.  The EPA has revised the compliance cost
estimates for  this facility by recategorizing the facility as
large, and assigning costs associated with a large line.   (See
Chapter  8 of the proposal BID  "Hazardous Air Pollutants from
Magnetic Tape  Manufacturing--Background Information  for Proposed
Standards," EPA-453/R-93-059  [item III-B-1 of Docket A-91-31]  for
a  description  of  costs  for  large  lines.)  Based  on this revision,
industrywide  annual  costs to meet the  standards  are  approximately
$822,000/yr,  with a  corresponding cost effectiveness of $390/Mg
of HAP controlled.   This reflects an increase  of $421,880/yr  in
annual costs  for  commenter  IV-D-16 to reflect  the change  in size
designation.
      The remaining commenters  however,  did not provide specific
 information on what  was incorrect'about  the EPA's proposed
 compliance costs.  Industry compliance costs are based on
 information that was solicited from industry during the
 development of the proposed regulation.   All specific information
 received from industry was considered carefully.  Commenters cite
 EPA's cost estimates of $2.26 million, which is for control
 equipment only.  The EPA also recognizes that facilities will
 incur costs associated with testing, monitoring, reporting and
 recordkeeping and these costs were considered separately.
      Comment:  One commenter  (IV-D-6) stated that Section VI.E  of
 the preamble  underestimates the  amount of spent carbon generated
 and overestimates the useful  life  of the carbon.  This
 commenter's facility operates two  carbon adsorption systems with
 a total of 80,000 pounds of carbon, and claims  even larger
 systems exist in the industry.   This  carbon is  changed every
 18 months  to  2 years.   Ketone solvents such as  those  used in  this
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  industry react with oxygen and heat,  producing compounds that
  foul  the carbon and reduce its useful life.   Additionally,  the
  life  of the carbon is  expected to decrease slightly due  to  the
  increased loading that will result from implementing the proposed
  standards.
       Response:   The proposal BID  notes  that  average carbon  life
  for individual  fixed-bed  carbon adsorbers  ranges  from 6  months to
  5 years  and from 3  to  5 years  for flu.-i.dized-bed carbon! adsorbers.
  To develop  cost  impacts of  the  standard, the  average  useful life
  of carbon in a  carbon  adsorption  system was estimated to be
  5 years.  The EPA recognizes that  it  is likely that some
  facilities will have systems with  longer or shorter carbon
  lifetimes.
      During development of the proposed standards, information
 was solicited from industry on the impact of controlling all
 emission points considered in the proposed standards with
 existing control devices.   From the information received, it was
 assumed that control of additional emission points with an
 existing carbon adsorption system would not decrease the life of
 the carbon bed and not  result in additional incremental' solid
 waste.  Therefore, the  amount of solid waste (spent carbon)
 resulting from use of a carbon adsorption system was calculated
 for the addition of new coating lines  only.  (it was assumed that
 uncontrolled facilities would install  a carbon adsorption system
 to  comply with  the standards.)   This impact was estimated to be
 less than 0.1 Mg/yr (0.01  ton/yr).   The  amounts of carbon solid
 waste  presented in the  proposal  BID are  incremental impacts  and
 do not represent the total amount  of carbon that a facility  would
 generate,  only  the additional carbon that would be generated as a
 result of the standard.                                 ;
 2.6  SELECTION OF  MAXIMUM  ACHIEVABLE CONTROL TECHNOLOGY (MACT)
 2.6.1   Selection of  the MACT  Plnnr-                      :
     Comment;  Two commenters  (IV-D-4,  IV-D-10) responded to
EPA's request for  comments on interpretation of the MACT  floor.
     The  first commenter (IV-D-4) stated that the MACT  floor
should be interpreted to be the 88th percentile of the best
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performing sources,  believing that this was Congress'  intent.
The commenter noted that the MACT floor interpretation will
affect the level of control required for HAP particulate transfer
operations by requiring enclosed transfer if the MACT floor is
interpreted as the 94th percentile.  However, if the MACT floor
is interpreted as the 88th percentile, the MACT floor for
particulate handling would be manual transfer while venting to a
99 percent efficient control device.
     The second commenter  (IV-D-10) argued that the MACT floor
should be interpreted as the average of the emission limitation
achieved by each source in the top 12 percent of a source
category.  In other words, the MACT floor should be calculated by
adding the emission limitation achieved by each source  in  the top
12 percent and dividing by the number of facilities in  the top
12 percent.  The MACT floor would not necessarily be .the level of
control of the source at the 94th percentile but could  be
stronger or weaker, depending on the  levels  of  control  above  or
below the 94th percentile.
     This commenter also claimed that  the  alternative
interpretation of emissions  control by  the  source at the
88th percentile  does' not represent  the average  emission
limitation achieved by  the top  12  percent  of sources.   The
commenter argued that to  interpret the  MACT floor as  the  level  of
control  at the  88th percentile  goes against Congress'  intent.   If
Congress  had intended the  floor to be the  emission  limitation
achieved by  the  source  at  the  88th percentile,  it would have
stated  so clearly.  Nothing in the legislative  history suggests
that Congress intended  general  language meant  to apply to the
 entire  toxic program to refer to the  average emission limitation
 achieved by a single  source.  Some sources emit a single HAP;
 these sources do not  achieve multiple emission limitations to be
 averaged.   Also, in cases where sources emit a complex stream,
 EPA would have to determine not just  the general efficiency of
 various technology but precisely how much reduction is achieved
 for each regulated pollutant.   Such an approach would  impose an
 enormous data gathering burden on EPA.
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      The commenter also argued that the purpose of  the MACT floor
 was to mandate the maximum achievable emission reductions  rather
 than have cost considerations lower the emissions level, citing
 Senator Dingell's introduction of the amendment to  establish the
 MACT floor.                                             ;
      Response:   On June 6,  1994,  the EPA promulgated a final rule
 (57 FR 29196)  that presents the Agency's interpretation of
 Section 112(d)(A)  of  the Act regarding the  basis for the MACT
 floor.   The Agency's  interpretation of this section of the Act
 agrees with the interpretation presented above by the second
 commenter.  Under this  interpretation,  which is referred to as
 the "Higher Floor Interpretation,"  the Agency considers the
 emission limitations  achieved by  the best performing 12 percent
 of  existing sources and arrives at  the MACT floor by averaging
 those emission limitations.   Furthermore, the Agency interprets
 "average"  to mean a measure of central tendency such as the
 arithmetic mean or median.   For example,  if a source category
 included fewer  than 30  existing sources,  the Agency would
 consider the five best  performing sources.   If  those sources
 achieve  emission reductions  of 99,  98,  95,  94,  and  93  percent,
 the arithmetic  mean of  the  five values would be 95.8  percent.
 Because  this value does not  correspond to an actual  control
 efficiency being achieved,  the Agency could set the  MACT floor at.
 95  percent, which is  the median of  the five values.     [
      The Agency has concluded that  if Congress  had  intended EPA
 to  set the MACT floor as the  lowest  reduction achieved by  the
 best  performing 12 percent  of existing sources,  as  suggested by
 the first commenter,  Section  112(d)(A)  would have been worded
 differently.  For example, Congress  could have  expressed such a
 meaning  by requiring  the floor to be  set  at  "the emission
 limitation achieved by  all sources within the best performing
 12  percent" or  at  "the  emission limitation  achieved by the  least
 efficient member of the  best  performing 12 percent."   Therefore,
 the Agency believes that such an interpretation, which  is
 referred to as  the  "Lower Floor Interpretation," requires that
words or concepts, which are  not stated explicitly in  the
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statute,  be added or inferred.   Furthermore,  the Higher Floor
interpretation is supported by Section 112 (d) (3) (B) ,  which
requires the MACT floor for existing sources in categories or
subcategories with fewer than 30 sources to be no less stringent
than the "average emission limitation achieved by the best
performing 5 sources."  To infer a Lower Floor Interpretation
from this provision, Congress would have used language such as
-the emission limitation achieved by the ^h bpst performing
source . "
262   Selection  of MACT                       •
     Comment:  One commenter  (IV-D-11)  stated  that MACT  standards
should be  at  least as  stringent  as  the  reasonably available
control technology  (RACT)  standards developed  in the 1980' s.   The
commenter  stated  that  the  state  of  New  Jersey  requires various
control techniques  for processes included in the manufacture of
magnetic tape (e.g.,  solvent  storage tanks,  wash sinks for
 removable  parts  cleaning,  etc.)
      Response:  The RACT for  this source category was established
 in 1977 and,  in general,  requires a VOC content of 347 grams per
 liter  (g/D of coating applied,  excluding water.  For typical
 coatings used by this industry this is equivalent to
 approximately 83 percent control .  The proposed standard requires
 a higher control efficiency of 95 percent and regulates more
 emission points within the source  category.
      Comment :  One commenter  (IV-D-13) recommended  that EPA-
 reevaluate MACT  for solvent storage tanks, mix  preparation
 equipment  and other pieces of equipment  to  consider factors  such
 as HAP concentration,  flow rate, and distance from  a control
 device, because  these factors influence  costs to control.   The
 commenter suggested  instituting a  Total  Resource Effectiveness
  (TRE)  index  as was done  for process vents in  the hazardous
 organic national emission standards for hazardous  air pollutants
  (NESHAP)  from the synthetic  organic chemical  manufacturing
  industry (hereafter referred to as the HON) .
       Response:   The MACT floor is based on the average emission
  limitation achieved by the best performing 5 sources (for which
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 the Administrator has or could reasonably obtain emission
 information) in a category that has fewer than 30 sources.  A
 MACT standard cannot be less stringent than the established
 floor.  For this source category there were five sources
 controlling all mix equipment and storage tanks; therefore, that
 portion of the MACT floor addressing mix equipment and storage
 tanks is based on an overall HAP control efficiency of
 95 percent.  Information obtained from the facilities was
 evaluated to determine if subcategorization based on size,
 distance to control,  etc. was reasonable.  Data for
 subcategorization either were not available or indicated that
 subcategorization was not justified (e.g.,  even the smallest
 tanks were controlled.)
      Comment:   Two commehters (IV-D-13,  IV-D-14)  noted that the
 proposed standard does not provide de minimis  levels for low
 emitting equipment.   One commenter (IV-D-13) also stated that it
 is not clear from the preamble or BID that  the portion:of the
 MACT floor for all tanks and mix prep equipment is 95 percent
 overall removal efficiency.
      The other commenter (IV-D-14)  stated that requiring
 95 percent controls on storage tank emissions  is  not cost
 effective.   The commenter explained that  with  50  percent control
 from conservation vents,  emissions  are approximately 500 pounds
 HAP per year from storage tanks  at  their  facility.   The
 regulation will  require  an expenditure of $15,000  to $20,000  to
 control  a  small  amount of HAP an additional 45 percent.   The
 commenter  estimated the  incremental  cost  effectiveness to achieve
 95  percent  control at  $60,000 to  $80,000  per ton.  The commenter
 asserted that  Congress did not intend  MACT to  impose  exorbitant
 costs on industry  to achieve  marginal  reductions in HAP
 emissions.                                             I
     Response;  As previously stated,  that portion of the MACT
 floor for mix equipment and storage tanks is based on the fact
 that there are five major sources in this source category that
 control all of their mix equipment and all of  their storage tanks
by at least 95 percent.  The Act does not allow a MACT standard
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with a level of control less stringent than the floor.   A review
of data indicates no reason to subcategorize certain mix or
storage tanks.  See Section 2.14.1 of this document for a
discussion of an alternate compliance plan that allows an owner
or operator to control coating operations at a higher efficiency
in lieu of controlling HAP emissions from storage tanks.
     Comment;  One commenter  (IV-D-13) suggested that EPA delete
from the definition of solvent recovery the phrase "to recover
the HAP, and to purify the HAP for reuse in the process."  The
commenter claimed that it is not apparent that the MACT floor was
properly established for recovery/purification equipment.  Also,
the commenter stated that inclusion of purification equipment in
the proposed rule penalizes facilities that purify solvents and
rewards facilities that destroy waste solvent or send it off site
for purification.  The commenter also noted that facilities
having closed loop recycling are exempted under the Resource
Conservation and Recovery Act  (RCRA) 40 CFR Part 261.4(a)(8).
The commenter asked if distillation units regulated by the
proposed rule are also covered under the RCRA air regulations for
distillation equipment in 40 CFR Part 264 Subpart AA.  The
commenter also questioned if EPA considered purification
operations that, in addition to magnetic tape solvents, handle a
variety of solvents that are not used in the magnetic tape
operation, stating that the MACT floor does not reflect
multipurpose purification operations.
     Response:  Regulation of  solvent recovery equipment  is based
on the MACT floor.  Information available to EPA indicates that
three facilities have wastewater discharges as defined  in the
rule, and use  steam stripping  to remove HAP from the wastewater.
Therefore, the portion of the  MACT  floor associated with
wastewater treatment operations is  based on the use of  a  steam
stripper or equivalent.  Likewise,  there are five  sources that
perform on site  solvent recovery and that vent HAP emissions  from
condenser vents  in solvent  recovery to the add-on  air pollution
control device.  Given this MACT  floor level of  control,  the  rule
must at least require  this  level.
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      The RCRA air regulations cited (40 CFR 264)  regulates
 process vents on distillation units.   Sources in the magnetic
 tape source category may be covered by this regulation.   In any
 event,  Subpart EE regulates emissions  from condenser vents in
 solvent recovery processes in the same manner as 40 CFR  Part 264.
 Subpart AA to Part 264 requires 95 percent control of volatile
 organic compounds (VOC)  or an exit concentration of 20 parts per
 million by volume (ppmv)  total organic compound for incinerators
 from closed-vent systems.   Therefore,'if a source is subject to
 both rules and chooses to control VOC  rather than HAP pnly,  as is
 likely,  there should be no conflict in control strategies.
 2.7   SELECTION OF COMPLIANCE DATES
      Comment:   Five commenters [IV-D-4 and IV-F-1 Tacconi,
 IV-D-13,  IV-D-14,  IV-D-15,  IV-D-16 and IV-F-1 Carlson): stated
 that the compliance time of 1 year from the date  of promulgation
 is too  short.   One commenter (IV-D-4 and IV-F-1 Tacconi)
 recommended changing the compliance date to a minimum of  2  years
 after the effective date of the standard,  or 3 years it a new
 control  device is  required.   The commenter maintained that  the
 standard may  require extensive retrofitting and/or installation
 of new  control equipment,  and that a minimum of 2  years would be
 required to adequately plan,  design, fund,  purchase,  and  install
 the  required new equipment.   If a new  emission.control, device is .
 required,  the  full  3  years  allowed under the Clean Air: Act would
 be needed for  compliance.   In addition the commenter claimed that
 allowing only  1  year to  comply would cause conflicts  if a
 facility requests a  1-year  extension under the General
 Provisions.  The extension must be submitted 12 months before  the
 compliance  date, which would  mean the  facility would  have to
 request  an  extension  on  the date  of promulgation of  the standard.
 However,  the facility would not  know before  the promulgation date
 if they would  need to request  an  extension,  since  the final  rule
would not have been promulgated.   Finally, there is no assurance
 that the State or Administrator would approve  the  extension.
     The second  commenter  (IV-D-16 and  IV-F-1  Carlson) suggested
a minimum of 27 months to comply with the  standard, based on a
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7-step work plan.   The commenter proposed the following
sequential work plan:  (1)  evaluate control technologies
 (2 months); (2) design specifications for the control technology
 (4 months); (3) obtain construction permit from the State
 (6 months); (4) obtain operating permit from State  (6 months);
 (5) obtain construction bids and contract negotiations
 (3 months); (6) procure control equipment  (6 months); and
 (7) construct  and test control system  (3 months).   The  commenter
 stated that its estimate of compliance time is supported by the
 experience of  a plant in Wales  (3.5 years) and a competitor in
 California  (3  years).  Although the commenter suggested that  the
 compliance period be no fewer than 27 months, they  recommended  a
 3-year compliance period.
      The  commenter  also asked that EPA consider  the role  of
 States in permitting the  construction  of  control devices.   For
 example,  the  State  of Nebraska  is  not  expected  to  have a
 formalized process  for  obtaining construction permits until
 November  1994.  Also, the State outline for obtaining a
 construction-permit suggests that 10 months may be required.   If
 the application is not  complete,  objections could arise from
 State review.  Furthermore,  legal, policy, or discretionary
 issues could arise from public notice of the application.  The
 commenter also pointed out that startup difficulties are
 possible, since this is a new program at the State.  In general,
 permitting under Title V is controversial and it is reasonable to
 expect delays before programs are fully implemented.
      The commenter  also stated that a 1-year compliance deadline
 is unrealistic.  The commenter estimated  that 10 months may  be
 required to  obtain  state and local permits; 4 to 9 months are
 required to  procure necessary equipment;  construction time is
 dependent  on weather conditions,  and  3 to 6 months may be
  required to  achieve maximum effectiveness of the  control device.
  The  commenter believes the  deadline  extension provision  does not
  eliminate the need for a longer compliance deadline.
       The third commenter (IV-D-13)  recommended allowing  existing
  sources  3 years after  the effective date to comply with the  rule.
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 The commenter stated that existing controls are for RACT or new
 source performance standards  (NSPS), which may be considerably
 less than the proposed MACT, depending on emission point.  For
 example, to increase control from 85 percent to 95 percent could
 require a new control device or expansion of capacity of an
 existing control device.  Also, the proposed rule covers a wider
 range of emission points, which may require a new control, device
 or expansion of the existing control device.  According to the
 commenter,  the time frame required to complete installation of
 new control equipment is typically 2 to 3 years.   Alternatively,
 the commenter suggested the regulation distinguish between
 sources currently (March 11, 1994 and earlier)  subject 'to the
 NSPS and sources not subject to the NSPS, and allow sources not
 subject to  the NSPS 3 years to comply.                  '
      The fourth commenter (IV-D-14)  stated that 1  year \±s not
 long enough for compliance.   The commenter explained that in
 Texas  construction permits  typically take from 6 to 9  months to
 be issued by the State,  and construction cannot begin  until the
 permit  is issued.   Equipment delivery takes  4  to 6 months,
 installation and startup takes  4 to 6 months,  and  design,
 permitting,  acquisition,  and installation can  take, a totzal  of
 18 to 27 months.   The commenter suggests  a compliance  date  of at
 least 30  months  after the effective date  of  the standard.
     The  fifth  commenter (IV-D-15)  remarked  that the compliance
 deadline  is  too  short  to allow  adequate time for a source to
 apply for an extension of the deadline.   The extension request
 must be  filed on the date the regulation  is promulgated.  The
 commenter suggested that  the MACT standard override  the|General
 Provision requirement of  1-year review of an extension request.
     Response;  After reviewing the comments received, the Agency
 recognizes that  the l-year compliance period for affected sources
 that was  specified in the proposed rule may be inadequate for
 some facilities.  For facilities that must install a new control
device, l year may not allow sufficient time for evaluating
available control technologies; obtaining construction and
operating permits; and procuring, installing, and testing
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controls.   In addition,  because this rule covers a wider range of
emission points than the NSPS,  some facilities that are subject
to the NSPS also may need additional time to retrofit the
emission controls necessary to comply with the MACT standard.
Therefore, the Agency has increased the compliance period to
3 years for affected sources that will need to install a control
device to comply with the control requirements of
Sections 63.703(c) or (g) of Subpart EE.
     All other magnetic tape manufacturing operation sources
would have to comply within 2 years of the effective date of the
standard.  The EPA believes that the timeframe for compliance can
be shorter for owners or operators that do not have to install a
new control device.  The greatest difference may be that such
sources would not have to obtain preconstruction and construction
permits.  Nor would such sources have to evaluate appropriate
control technologies, select vendors, and install the  control
device.   The EPA does realize, however,  that  even if a new
control device  is not needed,  an owner  or operator will  have to
evaluate  the feasibility of manifolding additional emission
points  into the  existing control device.  Also,  time will be
needed  to purchase and  install sufficient ductwork and process
controls, and  the performance  of the  existing control  device may
have  to be  optimized.
      The  final rule  specifies  that,  to  trigger a 3-year
 compliance  timeframe,  the  new  control device  must  be  installed to
 comply  with §  63.703(c)  or (g).  The  types  of control  devices
most  likely needed to meet these requirements are  carbon
 adsorbers,  condensers,  incinerators,  and steam strippers.   To
 comply  with the other standards, large-scale  equipment is  not
 needed  and compliance can be accomplished within the 2-year
 timeframe.   For example,  to comply with 63.703(d),  owners  or
 operators that must install an enclosed transfer device.  Because
 the ductwork and process controls  required to install such a
 device will not be extensive,  the  EPA does not believe owners or
 operators will need 3 years to complete the installation.   As an
 alternative to the enclosed transfer device,  owners or operators
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may use a baghouse or  fabric  filter.  However, this option is
most likely to be pursued by  owners or operators that already
have this equipment.   The standards for wash sinks and flushing
of fixed lines can likewise be achieved within 2 years.  A
freeboard ratio, at most, would require a new sink.  A closed
system for flushing fixed lines could be retrofitted on site.
     The Agency believes that these revised compliance timeframes
will allow facilities  sufficient time to bring affected sources
into compliance with the rule while ensuring implementation of
emission control in a  timely  fashion.  In addition, the increase
in the compliance time period will allow additional time for
State agencies to implement permitting programs required under
Title V of the Act.
     To accommodate sources that cannot comply with the standard
by the compliance date, 40 CFR Part 63.6 (i) of the General
Provisions allows owners or operators of affected sources to
request a 1-year compliance extension.  The request for extension
of the compliance date must be submitted 12 months in advance of
the compliance date.   Increasing the compliance period |to 2 or
3 years allows owners  or operators of affected sources at least
1 year to evaluate the need and apply for such an extension.
     Comment:  One commenter  (IV-D-ll) recommended that EPA
clarify that sources constructed between the proposal and
promulgation of this rule are entitled to a compliance extension
if they meet the requirements of the proposed rule.    ;
     Response:   Section 63.6(b)(3) of Subpart A clarifies the
compliance time for sources constructed between proposal and
promulgation.  According to this section,  owners or operators of
such sources shall comply with the standard no later than 3 years
after the effective date only if the promulgated standard is more
stringent than the proposed standard and the owner or operator
complies with the standard as proposed during the 3 year period.
If the final standard  is not more stringent than the proposed
standard,  the owner or operator of a new source must comply with
the final standard immediately upon startup.   The compliance
extension described in § 63.6 (i)  allows extensions of the
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compliance date only for existing sources.   Section 63.2 of the
General Provisions defines "new source" as  any source for which
the construction or reconstruction commences after the proposal
date   Therefore, if the construction of the source in question
is begun after the proposal date, that source is considered to be
a new source.  In effect, the fact that the source has 3 years to
comply if the promulgated rule is more stringent than the
proposed rule is an extension of the compliance date.
2.8  SELECTION OF EMISSION LIMITS AND EQUIPMENT/WORK PRACTICE
     SPECIFICATIONS
281  Periods when the  r.nater is Down
    ' comment:  Five commenters  (IV-D-4 and  IV-F-1  (Tacconi),
IV-D-9,  IV-D-13,  IV-D-14,  IV-D-16)  responded  to EPA's  request  for
comments  on options for  demonstrating  compliance with  the
proposed rule  during  periods  of  low inlet  concentrations to a
carbon adsorber.
      One commenter (IV-D-4 and IV-F-1  [Tacconi])  claimed that  an
 overall 95 percent control efficiency  is not  feasible when the
 coating process is not operating.   The commenter suggested
 including an equipment operating standard that requires only that
 the control device be in normal operation when mix preparation or
 other operations are emitting HAP.  The commenter also
 recommended requiring the owner or operator to maintain records
 to document periods when the coater is down and HAP are being
 emitted to demonstrate  that the control device is operated
 properly. ' The commenter argued that while 95 percent  control •
 efficiency can be achieved during  coating  operations,  when  the
 HAP concentration of  inlet stream  to  the control  device  is  high,
 this  level  cannot be  maintained when  the coater is  not operating
 because  the HAP  concentrations  from mix preparation and other
 operations are  too low  for control systems to achieve 95 percent
 control.
       The commenter did not believe that any  of  the three
 alternative compliance options  presented in  the proposal preamble
  to address control during noncoating  periods are acceptable.
 Allowing a longer averaging time  (Option 1), the commenter
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  claimed, would not be possible unless an extremely long averaging
  time was chosen.  Citing data submitted to EPA,  the cbmmenter
  stated that one of their facilities only achieves 90 percent
  control efficiency when using a 7-day averaging  period.
  Compliance with a 95 percent control requirement would likely not
  be achieved by existing facilities unless the averaging  time is
  30 days or longer.   Requiring a lower control efficiency during
  noncoating operations (Option 2)  would also be problematic
  because the minimum average control efficiency of an existing
  facility would be difficult to determine;  the duration!of
  noncoating operation time  cannot  be predicted and may vary
  significantly  among facilities.   Specifying a control  device
  outlet  concentration (Option 3) would  be  feasible; to  ensure  that
  all existing facilities could comply,  however, the limit would
  have to be  set  so high that  it would essentially be meaningless
  from an enforcement  standpoint.                        '
      According  to the commenter, any emission limits would need
  to be facility-specific and would not demonstrate 95 percent
 control efficiency.   The commenter suggested that EPA establish
 an alternative acceptable minimum emission concentration that a
 facility could adopt for compliance without having to determine
 its own facility-specific control limit.  This would minimize
 test burdens on facilities  which may not be able  to economically
 shut down all coaters for a 72-hour or longer compliance  test to
 simulate emissions during extended periods of noncoater!
 operation.   Instead,  a continuous  emission monitor (CEM)  could be
 used to  measure HAP  emissions during these periods.     ! '
     The second commenter  (IV-D-13)  recommended that  EPA  allow
 the owner/operator to establish either  the control  efficiency  or
 outlet concentration as a site specific operating parameter
 during the  initial performance test  required in §  63.704  of the
 proposed rule for periods when the coater  is  down.  However  the
 commenter does not have specific data to propose a specific'value
 for an alternative control efficiency or outlet concentration  for
when the coating operation is  down.  The commenter also Requested
that the owner/operator be exempt from control requirements
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during those periods of time (weekends,  holidays,  etc.)  when the
facility is not operating, the control device is shut down and no
emissions are being routed to it.
     The third commenter  (IV-D-9) suggested that EPA allow an
alternate emission limit for control equipment other than
incinerators.  Specifically, when emissions from the control
device are below the detection limit, the source should be
considered to be in compliance.  The commenter reasoned that when
a coating line is not operating, the inlet concentration to the
control device could be so small that to comply with the overall
control efficiency, the outlet concentration would have to be
below the detection level.  In this  case the overall control
efficiency cannot be demonstrated.
     The fourth and fifth commenters (IV-D-14,  IV-D-16)
recommended  an averaging  period  of  30 days for  carbon adsorbers
to  account for periods  of low  inlet  concentrations.  One
commenter  (IV-D-14) explained  that  a predetermined outlet
concentration  is unworkable due  to  highly variable inlet
concentrations.  Also,  a  3-day averaging period is not  feasible
since  some  facilities  shut  down on  weekends  and holidays,  and for
maintenance.  Based on their  experience the  commenter  suggested a
30-day averaging period to  average  out  the  low inlet
concentration  times during  regular  or seasonal shutdowns.   The
other commenter (IV-D-16) alternatively recommended  specifying a
maximum emission  rate of  5  percent  of the maximum design inlet
VOC load to the control device,  or  recommended simply requiring
 operation of the  control  device whenever  other affected emission
 points are emitting HAP during noncoating periods.
      Response:  At proposal,  the EPA requested comments on the
 feasibility of a 95 percent control efficiency for solvent
 recovery devices when the inlet concentration and flow to the
 control device are low; e.g., when  coating operations are down.
 The control efficiency during periods of low inlet concentration
 is a particular concern  for owners  or operators using carbon
 adsorption  units to comply with the proposed rule because one way
 to demonstrate continuous compliance is to continuously measuring
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 the percent efficiency.  Commenters agreed that this was a
 problem, but were not in agreement on the best way to address the
 problem.  Several commenters did suggest extending the averaging
 period to 30 days to account for periods of low inlet conditions.
 The EPA does not believe that this is an acceptable alternative;
 no data were submitted to support that this is the minimum
 averaging time that is technically feasible.          '•
      Commenters also did not support the option of an owner or
 operator establishing an alternate outlet concentration
 requirement for periods of low inlet conditions.  Primarily,  the
 reasons cited were that it would be costly to simulate; all
 possible modes of operation during an initial performance test,
 and outlet conditions are source-specific and depend greatly on
 highly variable inlet conditions.  The EPA recognizes that it
 could be costly simulate all possible modes of operation during
 one performance test.   Given the site-specific nature of outlet
 conditions,  however,  for EPA to set such an outlet concentration
 to apply to the entire industry during periods of  low inlet
 condition would be unfounded as EPA currently has  no data to
 support such a limit.   The  EPA does believe,  however,  that
 compliance with a site-specific alternate outlet concentration is
 the best  way to establish compliance  during those  periods when
 the inlet HAP  concentration to  the  control  device  is  low,  and
 that  the  value of the  alternative outlet  concentration;should be
 set by the source.                                     >
     There are  two alternatives  in  the  final  rule  for
 establishing the  site-specific  outlet concentration  for periods
 of  low inlet concentration.   Section  63.704(b)(11)(ii) allows  the
 owner  or  operator to conduct  a performance  test  during which  the
 coating operations are not  occurring, and the  control device  is
 operated  according to good  control practices in  the same manner
 as  it was  operated to achieve the emission limits  for coating
 operations.  As stated above, this may be very burdensome for
 some sources.  Therefore, to minimize the burden on affected
 facilities, the final rule also allows sources to establish this
number using CEM data collected under such conditions as noted
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above, since carbon adsorbers will already have CEM's.  The final
rule  [§ 63.704(b)(11)(ii)]  allows owners or operators 6 months
after the compliance date to collect these data and submit a
proposed limit to the Administrator or permitting authority, as
appropriate.  In accordance with the final rule, the alternate
concentration limit will be approved (or disapproved) within
60 days of the receipt of the information necessary to grant the
approval  (or disapproval).  The EPA recommends that,  in general,
the limit be set as the highest outlet concentration measured
during periods of low inlet conditions.
      To support the alternate concentration limit,  the owner or
operator must also fulfill the reporting requirements in
§ 63.707(k).  In general, these require the owner or  operator  to
submit the CEM data collected since the compliance  date,  records
of when coating operations were down,  the rationale for the
alternate  proposed limit, and a statement signed by a responsible
official  of the company that states that, when the  CEM data were
collected,  the control device was  operated  in accordance  with
good  air  pollution control practices,  and in  the same manner  as
it was operated to achieve compliance  with  the emission
limitation for coating operations.
      The  alternate concentration  limit in the final rule  is
available to  all  owners  or operators  except for those with
 incinerators, but is  expected to  be used primarily by those
 owners or operators  using a  carbon adsorption unit.  Owners or
 operators using  an incinerator can comply with the alternate
 concentration limit  of  20 ppmv as allowed in the' proposed and
 final rules.
      The final  rule also clarifies when the emission limitations
 apply.  The emission limitations apply at all times during which
 the facility is  operating,  including times of startup and
 shutdown".  The emission limitations do not apply when the
 facility is not operating;  i.e.,  when mixing, coating operations,
 waste handling,  and solvent recovery involving HAP solvent are
 not  taking place.
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 2.8.2  Standard for Particulate Transfer              ;
      Comment:   Four commenters (IV-D-4,  IV-D-13,  IV-D-14,
 IV-D-16)  suggested alternatives to or clarification of;the
 enclosed transfer requirements for particulates.   One commenter
 (IV-D-13)  recommended that EPA limit requirements of particulate
 transfer operations to those particulates that may become
 airborne.   The commenter suggested that  a broad definition  of
 particulate could require an enclosed transfer system in cases
 where there is virtually no opportunity  for the particulate to
 become airborne.   One example of  this situation would be when
 magnetic particles are mixed into a liquid that forms a slurry
 and then transported in a closed  container to the mix preparation
 equipment.                                             ';
      Another commenter (IV-D-4) recommended that  EPA elaborate on
 the definition of "enclosed conveyor system" to include different
 types of enclosed transfer operations.   The commenter stated that
 it  uses several different types of equipment to transfer
 particulate material.   For example,  some particulate material is
 purchased  in "supersack"  containers,  which have attached feed
 tubes that  are attached and sealed directly to mix preparation
 equipment.   Also,  the  commenter uses  enclosed mechanical systems
 for particulate HAP transfer,  such as augers and  conveyors,  which
 it  believes should also meet  the  criteria for the "enclosed
 transfer method."                                      '.
      This  commenter also  recommended  that EPA allow the use of
 manual  charging of particulate HAP into  kettles with the use of a
 99  percent  efficient dust collector as an equivalent method to
 enclosed transfer.   The commenter estimates a 99.975 percent
 control efficiency for  its  own facilities.  The commenter also
 claims  that additional  costs  to convert  to  enclosed  transfer
 would be excessive compared to the resulting emission reductions.
 The commenter  noted that  enclosed transfer  systems all have some
purge capability usually  associated with  a  fabric  filter that
would vent  to  the  atmosphere.  Therefore, the ultimate difference
between enclosed transfer and open transfer with  control would be
minimal.  Lastly,  the commenter believed  EPA incorrectly
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established the MACT floor for participates and that it should
have set the floor equivalent to the 88th percentile,  which would
be manual charging of mix kettles with the use of a 99 percent
efficient control device.
     The third commenter  (IV-D-14) recommended that the proposed
rule be amended to require capture and control of at least 95 of
particulate emissions or the use of an enclosed transfer method.
The commenter stated that performance standards are almost always
superior to design standards, which are used only as a last
resort when performance standards are not possible.  Their
facility vents the particulate HAP unloading area to a baghouse
with greater than 99 percent  control of particulate emission
greater than 1 micron in  diameter, which  they believe  is at least
as  efficient as  the  enclosed  transfer method.
     This  commenter  also  recommended that EPA  create  an exemption
for 200 pounds  or less  of particulate HAP per mix batch used  in
research and development  processes.  The  commenter  explained  that
research and development  processes  use  many small batches  of
coating slurry with a particulate content of as little as  6  grams
to 200  pounds;  it  is unreasonable to  expect all research  and
development applications to use dust  control equipment standards
 for such small quantities.
      The fourth commenter (IV-D-16) believes that the regulation
 of particulate HAP emissions is unnecessary.  The commenter
 recommended eliminating the requirement for totally enclosed
 particulate HAP transfer operations for existing facilities
 because it is overly restrictive, costly, and unnecessary.  The
 commenter noted that current powder handling practices achieve
 best available control technology  (BACT) for particulate HAP.
 Because particulate HAP are  the most expensive component,
 handling procedures have been developed  to  minimize fugitive
 emissions.  The commenter further stated that  the proposed
 standard  is not practicable  -in  some situations, maintenance  costs
 will increase,  and  research  and development efforts will be
 impeded as a  result of  this  requirement.
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      Response:   In the  final  rule,  the requirements for
 particulate transfer operations have been revised and' clarified.
 First, the term  "particulate  HAP transfer" has been defined as
 the introduction of a particulate HAP into other dry ingredients
 or a liquid solution.   It is  during this charging, or transfer,
 that particulates become airborne.  One commenter suggests that
 transferring particulates into a liquid slurry prior to
 introducing them into mix vessels should not be regulated.
 However,  the manner in which  the particulates were introduced
 into the liquid  to form a slurry is of concern, and would be
 covered by this  subpart.
      The final rule now contains two standards from which to
 choose.  The first is the standard proposed:   the use of enclosed
 transfer device.   The definition of an enclosed transfer device
 was left  as a broad definition so as not to exclude equipment
 that could achieve enclosed transfer.   The supersack containers
 described by one  commenter would appear to meet the definition,
 as would  the mechanical  systems.   The  final  rule references such
 equipment.                                             !
     The  final  rule also allows  owners  or  operators  to;control
 emissions of particulate HAP by  venting  the  transfer operation  to
 a  baghouse,  dust  collector,  or fabric filter  that  exhibits no
 visible emissions while  controlling  particulate HAP  transfer
 operations.  The  minimum ventilation rate needed to  capture HAP
 particulates for  delivery to the control device would have to be
 supported by the  owner or operator by submitting engineering
 calculations  [§ 63.707(h)].  Guidelines to determine the
 appropriate ventilation  rate may be  found in  the Industrial
 Ventilation Manual of Recommended Practice, published by the
 American  Conference of Governmental  Industrial Hygienists
 (ACGIH).  The final rule  contains test methods and procedures for
 determining that  there are no visible emissions from the baghouse
 or dust collector [§ 63.705(g)],  as well as monitoring provisions
 for demonstrating continuous compliance [§ 63.704(e)].  :
     As stated in Section 2.4 of this document, research and
laboratory operations, including mix equipment used for research
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purposes, are not covered by this subpart.  The EPA disagrees,
however, with the assertion that particulate HAP should not be
regulated by this subpart.  A review of the control of
particulate HAP in the industry indicates that there are five
sources controlling emissions of particulate HAP.  Section 112(d)
requires that EPA set an emission limitation that is no less
stringent than the level of control being performed by the best
performing 5 sources for source categories  (such as this one)
with less than 30 sources.  Because a  "floor" level of control
exists  with regards to .particulate HAP emissions, the EPA  cannot
establish an emission limitation that  is  less stringent than that
portion of the floor addressing particulate transfer; to not
regulate emissions of particulate HAP  would be  less stringent.
     Comment:  One commenter  (IV-D-4)  suggested defining
 "particulates  that contain HAP," as worded in  § 63.703  of  the
proposed rule, as particulate material with a minimum HAP
 concentration  of 2 percent by weight.  This definition  would
 include typical  HAP materials such  as  cobalt-doped iron oxide
 (3 to  5 percent  cobalt  by weight) and  chromium oxides (62  to
 68 percent chromium),  but would avoid  excessive control
 requirements on  processes using particulate materials that
 contain HAP only as  a trace constituent  or contaminant.
      Response:  The EPA does not have data to support a
 definition of affected particulates as those that have a HAP
 content greater than or equal to 2  percent by weight.  The EPA
 believes that the final rule is clear in the types of
 particulates that are to be regulated.  Specifically, only those
 particulates that contain HAP and are involved in a transfer
 operation are regulated.  Further,  the final rule clarifies that
 it is  only those particulate HAP associated with magnetic tape
 operations that are covered by this subpart.   The EPA is  not
 aware  of other particulates  that contain HAP  (even in trace
 amounts) that are in use, and does not support a limit that would
 exempt particulate containing any HAP that is  associated  with
 magnetic tape operation.
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 2.8.3  Requirements for Wastewater                    ;
      Comment:  One commenter  (IV-D-4) maintained that EPA does
 not have sufficient data to set the concentration limit for
 wastewater streams from the steam stripper at 50 parts•per
 million by weight (ppmw) HAP.  The commenter noted that the data
 to support the limit was not obtained by test Method 305 of
 Appendix A to 40 CFR 63.                              '
      One commenter (IV-D-14) suggested that EPA amend the
 wastewater treatment requirements to specify a performance
 standard of 99 percent efficiency or an exit concentration of
 50 ppmw of total HAP.   The commenter argued that facilities that
 do not use steam stripping should not have to seek EPA;approval
 to use reliable technologies with demonstrated efficiencies in
 treating wastewater.   The commenter noted that heated '
 distillation columns  reliably remove organics to less than
 50 ppm;  also,  carbon  adsorption is a reliable and common method
 to remove trace amounts of VOC from wastewater.
      One commenter (IV-D-13)  endorses  the option of  alternative
 techniques  to  steam stripping to meet  wastewater requirements but
 objects  to  the basis  for establishing  the required removal
 efficiency/outlet  concentration.   The  commenter  recommended that
 EPA either  (1)  limit the rule only to  methyl  ethyl ketone  (MEK),
 methyl isobutyl ketone  (MIBK),  and toluene  and make  an adjustment
 for the  removal efficiency  for MEK described  in  the  HON; or
 (2) conduct another MACT floor evaluation to  include aljl HAP  and
 repropose this  portion  of the  rule.  The  commenter was concerned
 about the method used to establish the MACT floor for wkstewater
 treatment systems.  The  commenter  noted that  in  the  HON the
 removal efficiency required for MEK is only 95 percent.  Also,
 the removal efficiency and  outlet  concentration  is highly
 dependent on the type of HAP compound present  in the  wastewater.
 For example, the HON lists  a removal efficiency of 31 percent for
methanol.  If wastewater is combined with other process!
wastewater prior to stripping,  other HAP may be introduced which
could lower the actual removal  efficiency achieved by the
stripper.

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     Response:   The wastewater provisions in the final rule
differ slightly from those at proposal.   The EPA agrees that the
rule should not limit treatment methods to steam stripping for
removing HAP from wastewater.  Therefore, the final standards are
expressed in terms of performance limits, not technology.  An
owner or operator must achieve a certain fraction removed for a
given HAP, or must achieve a total VOHAP outlet concentration
less than 50 ppmw.  The volatile organic hazardous air pollutant,
or VOHAP, concentration is defined in the final rule as the
concentration of an individually-speciated HAP in a wastewater
discharge that  is measured by Method 305 of Appendix A to 40 CFR
Part 63.  The standard is clear that an  owner or operator is
required  to meet only one of these requirements; the  outlet
concentration or the HAP-specific fraction  removed.   Any ^
technology  can  be used to meet these limits as  long as  it  is
demonstrated to meet the  standards in accordance with the  test
methods and procedures in the  rule, and  as  long as approved
continuous  compliance monitoring  is conducted.
      At proposal,  the EPA explained that the  fraction removed and
outlet VOHAP  concentration  limits were based on data  gathered
 from this industry,  and  further supported by data gathered during
 development of the Hazardous Organic  NESHAP (HON--40  CFR Part 63,
 Subpart G).  In both the proposed and final rules,  the fraction
 removal requirement depends on the HAP compound in the
 wastewater.  As pointed out by commenter IV-D-13,  the
 requirements of the final HON rule differ from those at proposal
 and Subpart EE should also be revised.  Section '63.703(gj of
 Subpart EE requires the fraction removed specified in Table 9 of
 40 CFR Part 63, Subpart G of the HON for HAP compounds from
 magnetic tape manufacturing operations  that may be present in
 wastewater.  Therefore, MEK must be removed by 95 percent, and
 MIBK  and toluene must be removed by 99  percent.  These  fraction
 removed values, and the  others in Table 9  of Subpart G, were
 determined by  EPA  in developing  the HON and were based  on
 vapor-liquid equilibrium data for each  compound considered.  The
 removal  efficiencies should not  differ  for magnetic  tape
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  manufacturing operations.   The final rule also specifies that the
  HAP that must be removed are only those that are from magnetic
  tape manufacturing operations.   Thus,  if methanol is in the
  wastewater stream,  it must only be removed by 31 percdnt as
  specified in  Table 9 in 40 CFR Part 63,  Subpart G.   If the
  methanol is not  from magnetic tape manufacturing operations,
  Subpart  EE does  not require that it be  removed.        !
       The test method to be used to demonstrate  compliance with
  the  removal efficiency  is  unchanged from proposal, but! is
  clarified in the  final  rule.  In the final  rule,  owners  or
  operators may demonstrate  compliance with the outlet   i
  concentration or  removal efficiency by analyzing  the wkstewater
  for HAP using Method 305.   This method is the appropriate
 method for measuring VOHAP  concentration because  it quantifies
 the emissions potential from a wastewater stream, not just the
 concentration of the HAP in the stream at the time the!sample is
 collected.  Section 63.705(b)(9)(i) explains how to interpret
 data from Method 305 when an outlet VOHAP concentration is being
 demonstrated.   Method 305 is also used to demonstrate compliance
 with a percent efficiency.   As explained in § 63.705(h)(3)(ii),
 the inlet and  outlet VOHAP concentration must then be adjusted'by
 a factor to obtain HAP  concentrations;  the factor is  compound
 specific and is found in table 34 of 40  CFR Part 63,  Subpart  G.
      As an alternative to Method 305,  §  63.705(b)(9)(ii)  allows
 owners or operators to use  any test method to measure HAP that
 has been validated according to  Method 301 of Appendix A to
 40  CFR Part 63.   When an alternate test method is used7i and an
 owner or  operator is complying with the  outlet VOHAP    i
 concentration limit, the HAP concentration measured rausf:  be
 corrected to obtain  a VOHAP concentration.   As stated  in
 § 63.705(b) (9)  (ii) (A), this  factor is found  in table 34^ of 40  CFR
 Part  63,  Subpart G.  If  demonstrating compliance with the  percent
 efficiency limit and using an alternate test method to measure
HAP, no adjustment is necessary.                        ;
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2.8.4  Miscellaneous
     Comment:   Three conimenters (IV-D-4,  IV-D-14,  IV-D-16)
recommended that EPA allow an equivalent compliance limit for
reductions in HAP for facilities that use water-based coatings or
reduce the amount of HAP applied per unit of tape manufactured.
     The first and second commenters (IV-D-4, IV-D-14) stated
that this would be consistent with the NSPS, and would encourage
pollution prevention.  The first commenter suggested a limit of
0.143 kilograms  (kg) of HAP per liter  (L) of coating solids,
which is calculated by multiplying the VOC limit in the NSPS by a
ratio of 0.05/0.07 to reflect the 95 percent control requirement
of the NESHAP compared to the 93 percent control requirement of
the NSPS.  The second commenter suggested a HAP coating limit
similar to that  calculated in the magnetic tape NSPS.
     The third commenter  (IV-D-16) suggested a limit  of 0.12 kg
VOC emissions per kg of solids, which  they claim equates to
95 percent control  for a  coating that  is applied at 30 percent
solids and 70 percent VOC.  The commenter also suggested that
emissions be averaged on  a monthly basis, not a 3-day rolling
average, which  it claims  is not practical.
     Response:   The EPA recognizes the advantages  of  a low-HAP
coating  limit and has therefore included such a limit in the
final  rule  as a means of  encouraging pollution prevention.   The  .
final  rule  includes a HAP coating  limit, whereby  owners  or
operators are exempt from requirements for  a coating  operation if
a coating  containing less than 0.18  kg of HAP per L of  coating
solids is used  for  that  coating operation.   This" limit was
calculated  using the same methodology  used  to establish  the
alternate  limit for the  NSPS.   The low-HAP  coating limit in
Subpart EE  was  calculated by applying  a 95  percent efficiency to
a typical  coating containing 0.8  gallons of solvent per
 0.2 gallons of  solids,  and that has a  coating density of
 7.5 pounds  of solvent per gallon of coating.  Data collected from
 industry to support the NSPS found the typical  magnetic tape
 coating to be 80 percent solvent and 20 percent solids,  and these
 coating parameters were used in developing the low-VOC coating
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 for the NSPS  (0.25 kg  solvent/L  coating  solids).   In  the case of
 Subpart EE, all solvent  is  considered HAP; whereas  in the NSPS,
 all solvent was considered  VOC because VOC's are regulated by the
 NSPS.
     The EPA believes  that  the differences in the  coating limits
 suggested by the commenters (0.143 kg HAP/L coating solids and
 0.12 kg VOC/L coating  solids) and the limit calculated by EPA can
 be traced to rounding  of the limit calculated in the  NSPS to
 0.2 kg solvent/L coating solids  and assuming a representative
 coating mix of 30 percent solids and 70  percent solvent,
                                                       I •
 respectively.
     As required by §  63.703(c)(5), owners or operators that opt
 to comply with the low-HAP  limit must determine the HAP content
 of each batch of coating used, in accordance with  the procedures
 in § 63.705(c)(5) of the final rule.  No averaging  period is
 applicable.  If a coating with an identical formulation is
 subsequently used, the original  calculations can be used to
 demonstrate compliance.  Section 63.706(f) requires the owner or
 operator using a low HAP coating to maintain records  of the HAP
 content of each batch  of coating applied, and records of the
 formulation data that  support the HAP content calculations.  In
 accordance with § 63.707(i)(2),  these calculated HAP  contents for
 each batch of coating  are reported as the monitored operating
parameter value in the excess emissions  and continuous'monitoring
 system performance report and summary report required by
 § 63.10(e).
                                                       i /
     Comment:  One commenter (IV-D-17) stated that  the:rule
                                                       i
 should not require that all vents on storage tanks  be sealed and
vented to the control  device because this may create  back
pressure and safety problems.  The commenter stated that vents
 are necessary to relieve excess  pressure, and that  the•
                                                       i
Occupational Safety and Health Administration (OSHA)  requires
 such relief vents.
     Response:  The EPA recognizes that pressure and  vacuum
relief valves are routinely installed for safety purposes.  It
was not the intent of the rule to preclude owners or  operators
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from continuing to use such equipment.   Section 63.703(j)  of the
final rule has been added to clarify this point.
2.9  SELECTION OF TEST METHODS AND MONITORING REQUIREMENTS
2.9.1  Site-specific Operating Parameters
     Comment:  Two commenters  (IV-D-1,  IV-D-7) recommended that
§ 63.704(b)(2) of the proposed rule, which establishes the
maximum temperature of vapor exhaust stream as the site-specific
operating parameter for condensers, specify where in the process
the vapor exhaust stream temperature should be measured.
     Response:  For condensers the temperature of the vapor
exhaust  stream should be measured at the condenser exit, and
should be located a sufficient distance from  the outlet such  that
ambient  temperatures do not bias the reading.
     Comment:  Two commenters  (IV-D-1, IV-D-7)  stated that  in
§  63.704(b)(4) of the proposed rule, which establishes  the
minimum  gas  temperature upstream of the  catalyst bed  and  the
minimum  gas  temperature difference  across the catalyst  bed  as
site-specific operating parameters  for catalytic incinerators,
more information  than temperatures  must  be recorded to  ensure
compliance.   According to  the commenter,  the  temperature  rise
across  the catalyst bed varies according to  the volatile  organic
compound (VOC)  concentration of  the gases going into the  bed.  A
parameter must be specified to indicate  the  VOC loading to the
 incinerator that  corresponds to different temperature increases
 across  the catalyst bed.
      Response:  The standard has been clarified to allow owners
 or operators to set a range of temperatures for the site-specific
 operating parameter to account for different operating conditions
 [§ 63.704(b) (11) (i) 1 .  Thus, when inlet.conditions vary,  the
 owner or operator will have a range of appropriate temperatures
 from which to determine compliance with the standard.
      Comment:  Two commenters (IV-D-1, IV-D-7) stated that in
 § 63.704(c)(3)(iv) of the proposed rule, which contains
 provisions for continuing compliance  for control devices other
 than carbon  adsorption, the phrase "or at an average outlet
 concentration exceeding the  site-specific operating parameter
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 value, as calculated for any 3-hour period..." does not make
 sense.  If "outlet concentration" means HAP concentration, it
 does not make sense to say that the concentration cannot exceed
 the site-specific operating parameter value since these are not
 always HAP or VOC concentrations.
      Response;  This section of the regulation has been
 clarified.  Owners or operators may not operate control devices
 in any way that violates the site-specific operating parameter
 provisions in those cases where the operating parameter is not a
 HAP or VOC concentration.
      Comment:   One commenter.(IV-D-4)  suggested EPA include in
 § 63.704 (c) (7) of the proposed rule,  which requires installation
 and operation of equipment to  measure the site-specific operating
 parameters,  a provision for a  5  percent variation of the
 operating parameter used to determine compliance.   The; commenter
 claimed that a 5 percent variation would still satisfy the
 requirements for maintaining a total  enclosure.   The commenter
 also pointed out that allowing a 5 percent variation would be
 consistent with the Magnetic Tape NSPS,  and would eliminate
 redundant  recordkeeping and minimize  confusion between:the two
 standards.   Specifically,  the  commenter suggested changing the
 wording of §  63.704(c)(7)  of the proposed rule by replacing the
 word "greater" with the phrase  "5  percent more."       '.
     Response:   As  previously  stated,  the final rule allows
 owners  or  operators  to  establish a range of operating parameter
 values  during  the initial performance  test to  account  for
 variation  in operating  conditions  [§ 63.704(b)(11)(i)].
 Therefore, the EPA  does  not believe it  is  necessary  to'specify an
 allowable variance.  Also, as each operation is different,  the
 actual  range of values  should be established by the  owner or
 operator of the affected source.                       '-
     .Comment:  One commenter (IV-D-6)  believed establishing water
and steam feed rates for continuous compliance monitoring could
impose restrictions on the proper  operation of the stripping
column.  The commenter stated that stripping columns can operate
efficiently at feed rates lower than originally designed.
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However,  the steam-to-feed ratio would differ greatly over the
range of feed rates.  The quantity of steam used and water
present in a distillation system is primarily dependent upon the
age and performance of the activated carbon used in the carbon
system.  Depending on when the compliance determination is
conducted, the parameter chosen could indicate noncompliance when
the column is operating properly.
     Response:  The rule has been rewritten to allow owners or
operators using a steam stripper the option of conducting a test
to determine the appropriate steam-to-feed ratio or a range of
steam-to-feed ratios that are appropriate for a variety of
operating conditions.  Testing to determine a steam-to-feed ratio
is an option, not a requirement, and therefore the costs  for
testing have not been included in the compliance costs for the
standard.
     As an alternative to using  the steam-to-feed ratio as the
site specific operating parameter, owner or operators are allowed
to monitor the  steam stripper outlet VOHAP concentration  on a
monthly basis to show continuous compliance with the standards.
Because the wastewater stream is not expected to be greatly
variable,  monthly monitoring was determined to be an adequate
frequency for determining  continuous compliance.
2.9.2  Test Methods
     Comment:   Two commenters  (IV-D-1,  IV-D-7)  stated  that  in
 § 63.704(b)(1)(ii)  of the  proposed  rule,  the use of  a  continuous
 emission  monitor  (CEM)  to  demonstrate  compliance does  not make
 sense  because this part  of the  regulation requires  the  owner or
 operator  to determine which parameters can be used  to  show
 continuous compliance,  and to determine the range  these
 parameters must be within to be in compliance.   The commenters
 further stated that in this section,  it is not  clear whether an
 inlet  and outlet CEM measurement can be used to show initial
 compliance (if such measurement can be used,  then state that this
 is an alternative to the initial compliance test),  or if it can
 be used only to show continuous compliance tin which case it
 should be reworded similar to § 63.704(b)(i)].
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      Response:  The language of the regulation has been revised
 to clarify that GEM's may be used to show continuous compliance
 with percent HAP removal provisions.  Use of CEM's to'show
 initial compliance is allowed according to § 63.705 (a)(1)  as an
 alternative to an initial performance test.
 2.9.3  Compliance and Monitoring
      Comment:   Two commenters (IV-D-4,  IV-D-14)  suggested •
 changing the material balance averaging period from 3 days to
 30 days.  The first commenter (IV-D-4)  recommended a 30-day
 averaging period for the rolling liquid VOC  material balance for
 affected coating operations controlled by a  dedicated solvent
 recovery device in §  63.705(c)  of the proposed rule,  instead of
 the 3-day averaging period proposed by EPA.   The commenter stated
 that a 30-day averaging period is consistent with  the ;NSPS,  which
 provides consistency and eliminates unnecessary additional
 recordkeeping.   Also,  the 3-day averaging period would not  be
 feasible for solvent  recovery systems with long adsorption
 cycles.   The solvent  used in one day would not necessarily be
 recovered in the same day,  presenting incomplete balances  in a
 short averaging period.
      The second commenter (IV-D-14)  recommended that  EPA  increase
 the 3-day rolling average for material  balance to  one calendar
 month.   The  commenter stated that a 3-day rolling  average  is
 impractical  and unreasonable, with overly burdensome
 recordkeeping  requirements.   The commenter further stated  that
 any facility that borders on 95  control  would probably not  use a
 material  balance mechanism to demonstrate compliance. ,
      Response:   The EPA has  increased the material  balance
 averaging time  period from 3  days to 7  days  in the  finja.1 rule.
 The EPA  agrees  that a 3-day  average may  not  be adequate to
 account  for  variability in recovered solvent due to changes  in
 production and  the adsorption cycle of  the solvent  recpvery
 device, as noted by the commenters.   However,  the EPA does not
 believe that 30  days  is necessary to achieve this,  and that
 7 days is a  reasonable averaging period  for  most facilities.
Model VOC rules  developed for RACT in State  implementation plans
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require a 7-day rolling period for material balance calculation
of the overall emission reduction efficiency of a solvent
recovery control system (e.g., carbon adsorber).  The EPA does
not agree with the commenters that a 7-day averaging period will
be more burdensome than a 30-day averaging period because the
records necessary to compute a material balance are of an ongoing
nature.  The only significant difference is that the overall
efficiency will be calculated on a 7-day cycle rather than a
30-day cycle.  An owner or operator who does not believe that
7 days is an adequate averaging period given their specific
solvent recovery circumstances, and who wishes to use alternate
compliance techniques may provide their reasoning in a petition
to the Administrator in accordance with §  63.705(j) of Subpart EE
and § 63.7 (f) of Subpart A.  Also, the final rule offers other
compliance provisions for users of solvent recovery devices.
     Comment:  One commenter  (VI-D-9) recommended that the
correction for the incinerator alternate emission limit  should be
changed from  3 percent oxygen to at least  7 percent oxygen.   The
commenter claims that 3 percent is too stringent for  incinerators
and is. more appropriate for boilers.  Incinerators typically
require more  excess oxygen.   For example,  the  NSPS for municipal.
waste  combustors requires  7 percent correction for oxygen.   Since
the incinerators that will be used to comply with  this NESHAP
will  operate  with an amount of excess air  that is  closer to that
of municipal  waste combustors, the commenter believed it would
seem  reasonable to require a  correction to at  least  7 percent
oxygen.
      Response:  After  considering  the comment  and  the affected
processes, EPA decided that  a correction  for oxygen  was  not
needed.   The EPA agrees  that  the  3 percent oxygen  correction
factor is more appropriate for boilers  or incinerators  that are
combusting streams with very little  oxygen.  Because most
emissions are generated from coatings as  they  dry,  the  solvent
stream to the incinerator is mixed with large  amounts of air.  A
correction factor  to a lower oxygen content would make  the
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 standard more stringent than intended.  Also, the rule was
 clarified that the 20 ppmv HAP limit is per HAP compound.
      .Comment;   Two commenters (IV-D-1, IV-D-7) recommended moving
 § 63.704(b) (5) (iii) of the proposed rule to the monitoring
 section because this section states that monitoring shall be
 conducted in accordance with the plan submitted to the
 Administrator unless the Administrator requires an alternate
 monitoring scheme.  The commenter stated that placing this
 requirement  in the compliance section is not consistent with
 § 63.704(b), which requires determination of the value; of the
 monitored parameter that shows compliance with the standard
 during the stack test.                                 j
      Response;  All of  § 63.704(b)  discusses compliance and
 § 63.704(b)(6) of the final rule specifies requirements for a
 total enclosure  operating parameter monitoring plan that must be
 submitted to the Administrator.   Several different parameters
 could be monitored to show compliance with a total enclosure.   In
 the plan of §  63.704(b)(6),  the  owner or operator proposes what
 parameter  will be monitored for' compliance,  the  value  of which
 will  be  set during capture efficiency testing.   This is
 consistent with  the rest of §  63.704(b),  which discusses
 compliance monitoring requirements.
      .Comment;  Two commenters  (IV-D-1,  IV-D-7) stated  that the
 sentence in §  63.704(c)(2)(ii) of the proposed rule, which reads
 "the  thermocouple  calibration  should be verified every 3  months,
 or the thermocouple should be  replaced,"  is  unclear and needs  to
 be reworded.    The  commenter questioned whether this sentence
 means that the thermocouple should be calibrated  every 3  months
 and if it will not  calibrate properly, it should be replaced,  or
 whether  it means that the  thermocouple should either be
 calibrated every 3 months  or if the  owner or operator  does not
 calibrate it,   they have to replace it.
     Response:   The regulation has been clarified.  The language
of the rule now states that either the thermocouple is :to be
calibrated properly or it is to be replaced.
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     Comment:   Two commenters (IV-D-1, IV-D-7) stated that the
phrase "no additional compliance monitoring is required" in
§ 63.704 (e) of the proposed rule, which specifies compliance
requirements for owners and operators complying through the use
of a solvent recovery device, is unclear.  The commenters were
not sure if it means that if the owner or operator recovers
solvent, they are exempt from §§ 63.704(c)(3) and  (4), which
discuss continuous monitoring requirements.   Furthermore, it  is
not clear what compliance is required.
     Response:  In the final rule,  compliance requirements for
solvent recovery devices are specified under  § 63.705(c)(1).  The
requirements of § 63.704(c) (1),  (2),  and  (3)  of the  rule and
§ 63.8(b)(2) and  (3),  (c),  (d),  (e),  and  (g)(1) and  (2), and  (f)
of the General Provisions do not apply  to  solvent  recovery
devices that control emissions  from an  affected coating  operation
only, and  for which  the  owner  or operator  performs a
liquid-liquid VOC material  balance.  Sections 63.704(b)(9)  and
 (c)(9)  clarify that  results from the  material balance calculation
may  be  used to demonstrate  initial  and  continuous  compliance  with
 § 63.703(c).
 2.9.4   Miscellaneous
      Comment:  One  commenter (IV-D-4) suggested that EPA require
 the  total  enclosure to be maintained only during actual coating
 operations, including  startup and shutdown,  to be consistent with
 the  NSPS.   The  commenter also noted that this is the only time
 emissions  from the  coater occur.   The commenter suggested that
 the  phrase "during  actual coating operations" be" added to
 § 63.704(c)(7)  of the  proposed rule.
      Response:   The Agency agrees with the commenter that the
 total enclosure may need to be maintained only during coating
 operations, including startup and  shutdown periods.  This
 approach is consistent with the NSPS for the magnetic tape
 industry.   The coater is not an emission source when it is not
 operating therefore, for those periods when  it is not in
 operation the total enclosure  is not necessary to meet the
 standards.  However, other potential HAP emission points within
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 the total  enclosure must also be considered.   For example,  if  the
 mix room is  located in the total enclosure,  the enclosure must be
 maintained when mix operations are conducted.   The rule now
 clarifies  that  an enclosure need only be running when HAP
 emission points in the enclosure are emitting  HAP.
      Comment:   One commenter (IV-D-4 and IV-F-1 Tacconi)  stated
 that §  63.704(c)(8)  of the proposed rule,  which contains
 requirements for vent  systems that contain bypass lines that
 could divert vent streams away from the  control device!,  should
 include computer monitoring of valve position  (i.e.,  limit
 switches for fully closed valve positions).  Computer monitoring
 allows  for continuous  remote monitoring  of any bypass of the
 control device.   According to the commenter, the lock-and-key
 configuration is  not feasible for most bypass  lines,  because they
 are used as  emergency  safety release vents.  The car-seal or
 rupture disk option, while feasible,  would be  an expensive
 retrofit for vents currently monitored by  position  indicators
 because of the  relatively large number of  bypass vents| in
 operation.   .                                          I
      Response:  The  request to maintain  computer monitoring of
 bypass  valves rather than retrofitting bypass  valves  with
                                                       i
 car-seals  or rupture disks is reasonable.  The Agency's  concern
 is  that bypass valves  not be unmonitored or allowed to; be opened
 unnecessarily,   thereby circumventing the control device(s) .  The
 regulation has been  revised to allow this  option for  bypass valve
 monitoring.  Specifically,  §  63.704(c) (10) (iii)  requires  that
 owners  or operators  ensure that  any  bypass valve" is in,the  closed
 position through  continuous  monitoring of valve position, and
 that  the monitoring  system be inspected  at least once  every
 month.   Section 63.706 (c) (2)  requires  that records be  kept  of  the
monthly inspections, and  of  any  time periods during which the
valve position was open.   Occurrences  in which flow is diverted
 to the  atmosphere  are  required to be reported  by §  63.707(i)(4).
     Comment:  One commenter  (IV-D-4)  recommended that:EPA allow
an exemption for monitoring  of solvent recovery process unit
 condenser vents that vent back to the primary  control  device.
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The commenter reasoned that emissions from these vents would be
controlled by the control device and monitored by CEM's;
therefore, no additional monitoring is required.
     Response:  The intent of the regulation was not to require
monitoring of condenser vents that are vented back to the primary
control device, because the primary control device would be
monitored.  The provisions of § 63.704(b)(2) and (c)(4) have been
reworded to exclude condensers associated with process equipment
such as distillation and stripping columns.
     Comment:  One commenter  (IV-D-13) recommended that in the
requirements for demonstrating compliance for a solvent recovery
device  [§ 63.705 (c) (1) (iii) (C) of the proposed rule]', EPA clarify
by example exactly what type of device might be suitable for
measurement of the amount of VOC recovered by the solvent
recovery device.  For example, the commenter suggested that a CEM
and a carbon adsorption system could be used as well as a
condenser to remove solvent.
     Response:  One possible scenario in which § 63.705(c)(1) may
be used for compliance determination is the case in which a
solvent recovery device  (such as a carbon adsorber or condenser)
is used to control VOC emissions, and the VOC solvent is
subsequently collected and reused.  For example, a source may use
a carbon adsorber to collect VOC, desorb the carbon beds with
nitrogen, and collect the recovered VOC solvent in a storage
vessel.  In this example, the measurement device used to
determine the amount of VOC recovered could be a scale on which
the storage vessel sits.  The same scenario could exist with a
condenser; condensed VOC solvent could be collected in a storage
vessel, the contents of which are weighed.
     The EPA does not think that a CEM would be an accurate
accounting of the amount of VOC solvent recovered.  Presumably,
the commenter was thinking of determining the VOC applied at the
coater, and assuming the VOC collected would be less than that
measured by the CEM.  There could be some difficulties with such
a procedure.  The inlet measurement will be the quantity of VOC
applied at the coater, which would likely be in terms of volume
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or weight of liquid.  The GEM is measuring the concentration of
the vapor exhaust; the flow rate would also need to be known to
calculate the quantity of VOC in the exhaust.  Even if this is
done, however, the comparison of a gas outlet stream to a liquid
inlet stream is inferior to the measurement of two liquid streams
such as in the example described above.  Note, however,; that an
owner or operator is not required to do a material balance when a
solvent recovery device is used to comply with the standards for
coating operations.  Other monitoring methods are also allowed,
such as GEM's on carbon adsorbers.
     Comment:  One commenter (IV-D-13) requested that EPA clarify
whether the provisions for demonstrating initial compliance by
type of control system found in paragraphs § 63.705(c)(1),  (2),
(3) and (4) attempt to describe every possible control scenario
and what is intended for control scenarios other than those
described in those paragraphs.  The commenter stated that other
control device scenarios are possible that are not described.
     Response:  The EPA has clarified the language of
§ 63.705(c)(3) in the final rule to state that the provisions of
that paragraph are appropriate "when a fixed-bed carbon adsorber
with individual exhaust stacks for each carbon adsorber vessel is
used to control emissions from an affected source."  The EPA
believes that with this clarification, paragraphs  (c)(1) through
(c)(4) cover all control device scenarios.
     As the commenter pointed out, paragraph  (c)(1) covers the
situation in which a solvent recovery device  (carbon adsorber or
condenser) is used to recover HAP solvent from 'affected coating
operations only, and compliance is demonstrated by performing a
material balance.  Paragraph (c)(3) describes compliance
                                                       l
provisions for the situation in which emissions from affected
sources are controlled by a fixed-bed carbon adsorption system
with individual exhaust stacks for each carbon adsorbed vessel.
Paragraph  (c)(2) basically encompasses all other situations.
Paragraphs  (c)(2) and  (c)(3) account for the situation,in which
nonaffected emission points may be controlled concurrently with
                                                       i'
affected emission points by instructing the owner or operator  (in
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paragraphs (c)(2)(ii)  and (c)(3)(ii))  to isolate or segregate
nonaffected emission points from affected emission points.  Thus,
if affected emission points and nonaffected emission points are
concurrently controlled, the owner or operator would ensure that
the nonaffected emission points are not operating during the
compliance test for this subpart.
     Comment:  One commenter (IV-D-9)  stated that EPA should
include in the design specifications that must be submitted to
demonstrate compliance  for wastewater steam strippers the
vapor-liquid equilibrium data for stripped compounds.
     Response:  Vapor-equilibrium data are helpful  for
determining the extent  to which a compound can be removed from  a
wastewater stream through steam stripping.  In the
RON  (59 FR 19402), the  EPA specified the  expected fraction
removed for each organic compound to be steam stripped.   The
fraction  removed was  determined based on  the vapor-liquid
equilibrium data for  a  given compound.  In this  rule,  the EPA has
again  specified the appropriate  fraction  removed by referencing
the  HON rule.  Therefore,  the  EPA does  not believe  that it is
necessary for  sources to submit vapor-liquid  equilibrium data.
      Comment:  One  commenter  (IV-D-9)  suggested that
 § 63.705(d)(2) of  the proposed rule,  which  specifies requirements
 for  the  initial  compliance demonstration for  facilities that use
piping or ductwork to direct  HAP emissions  from an affected
 source to a control device,  include language  to clarify that the
 compliance demonstration specified under this section is in
 addition to the  requirements  to demonstrate 95 percent overall
 HAP control efficiency.
      Response:  Section 63.705 contains provisions for
 performance test methods and procedures to determine compliance.
 Procedures to determine compliance begin with § 63.705(c).  This
 section specifies that sources subject to § 63.703(c), which is
 the 95 percent overall HAP control efficiency requirement, must
 demonstrate initial  compliance by following procedures of
 paragraph  (c) and  (d)  among others.  Therefore, it is  clear  that
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 the requirements of § 63.705(d)  are in addition to those
 necessary to demonstrate 95 percent overall control efficiency.
      Comment;   One commenter (IV-D-13)  stated that a compliance
 demonstration should be based on inlet and outlet HAP
 concentrations with the option available for the owner or
 operator to measure VOC concentrations.   The commenter maintained
 that the owner/operator should have the option of deciding
 whether to measure only HAP or all  HAP and non-HAP that fall
 under the definition of VOC under this subpart.
      Response:   The intent of the proposed rule was to include
 the option of  measuring VOC as a surrogate for HAP to make the
 rule more flexible.   However,  as written the proposed rule
 requires measurement of VOC in some cases instead of HAP.   The
 commenter is correct that  the owner or operator should1 have the
 option of deciding whether to measure  HAP or VOC,  and the
 regulation has  been revised to make this clear.        |
      Comment:   One commenter (IV-D-13)  requested that EPA  clarify
 the term "steam-to-feed ratio" and  provide an alternative  to
 continuous measurement  of  this parameter for operations  which
 have batch feed.   The commenter  suggested that organics  may be
 added to a steam stripper  in batch  mode  and then the steam may be
 applied.
      Response:   The  steam-to-feed ratio  is  calculated in the same
 way for  batch as  for continuous  operations.   It  is  the mass of
 steam applied per liter of  wastewater feed.   Measurement of the
 steam-to-feed ratio  is  required  only when the stripper! is
 operating.   Thus,  for batch operations,  the  steam-to-feed  ratio
 would only be monitored while a  batch is  being fed  to the
 stripper.   In the  final  rule, owners or  operators may
 alternatively monitor the total  VOHAP concentration  of the
 wastewater discharge  on  a monthly basis.
 2.10   SELECTION OF REPORTING AND RECORDKEEPING REQUIREMENTS
     Comment:  Two commenters  (IV-D-1,  IV-D-7) stated that  the
 owner or operator should be required to  calculate monthly usage
and also calculate a  rolling 12-month total usage to compare to
the usage thresholds  in  § 63.701(a)(2)  of the proposed rule.  The
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annual report would include each of the previous 12-month totals.
If one of the thresholds in § 63.701(a)(2)  is exceeded, the owner
or operator must report within 30 days and comply with the
standard within 1 year of the exceedance.
     Response:  The EPA agrees that HAP usage should be
calculated on a monthly basis for those owners and operators that
meet the requirements of § 63.703(b) of the final rule and that
the owner or operator should report an exceedance within 30 days.
An exceedance would be a violation of the HAP usage limit.
However, in the final rule, EPA has clarified that the source
shall be required to comply with the control requirements for
major sources only if the owner or operator chooses to no longer
be subject to the HAP usage limit and  in doing so becomes a major
source.  In such a case, the owner or  operator would be required
to have the same amount of time to comply with the control
requirements as would an existing source, according to
§ 63.6(c)(5) of the General provisions.  The HAP usage limits
would continue to apply until the control requirements are met.
      Comment:  One commenter  (IV-D-9)  suggested that § 63.707(h)
of the proposed rule  (HAP utilization  reporting schedule) should
allow the  implementing agency to specify that date by  which a  low
HAP usage  facility must report.  The commenter  stated  that the
30-day deadline for reporting in the proposed standard may not
coincide with the requirements  of State  reporting  programs.
According  to  the commenter,  allowing the implementing  agency  to
specify  reporting dates would avoid multiple submittals  of annual
usage data by a facility.
      Response:  The final  rule  (§  63.707(j)) has been  clarified
to  state that owners  or  operators  reporting annual HAP
utilization to  comply with § 63.703(b) must submit the first
annual  report within  30  days of the compliance  date of the
standards.  On-going  reports are required  to be submitted
annually.   The  EPA is required  to  specify  the minimum reporting
and recordkeeping  for the final rule;  States with existing
programs in place  may submit their programs to  EPA for -approval
as equivalent in accordance with Subpart E of  Part 63.  Also,
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 § 63.10(a)(5) of Subpart A specifies that the dates by which
 reports must be submitted under Part 63 may be made consistent
 with the established reporting timeframes of a State with
 authority to implement the part.  Such changes must be mutually
 agreed upon by the owner or operator of the affected source and
 the State, be implemented in accordance with § 63.9(i) of
 Subpart A, and can begin 1 year after the affected source's
 compliance date for a relevant standard.
      Comment:  Three commenters (IV-D-04,  IV-D-9, IV-D-13)  stated
 that keeping records of the freeboard ratio each time liquid is
 added to wash sinks be eliminated.  Instead,  commenters suggested
 that the maximum solvent liquid level that would meet the
 freeboard ratio should be clearly marked by a suitable '.mechanical
 or physical means.   Two commenters (IV-D-04,- IV-D-13)  suggested
 language that stated:   "Follow a written procedure which ensures
 a minimum freeboard ratio of  0.75  is  maintained each  time HAP are
 added to the wash sink."   One commenter (IV-D-09)  also stated
 that compliance with the  freeboard ratio should also  be  required
 when a part is  submersed.
      Response;   The final  rule states that owners or  operators of
 wash sinks  containing  HAP  must limit  HAP emissions by maintaining
 a  freeboard ratio of 75 percent at all  times.   Therefore,  the
 freeboard ratio requirement would  be  in effect  when a part  is
 submersed.   The  final  rule [§  63.705(e)(1)] also  clarifies  that
 the  freeboard ratio may be determined by physical  means,  such as
 a mark  on a  tank that  indicates  the solvent level  corresponding
 to a 75 percent freeboard  ratio.   As  such, records could  involve
 keeping a checklist to document  that  the freeboard ratio  is at
 the  appropriate level every .time that solvent is added to the
 sink.                                                  |
     Comment;  One  commenter  (IV-D-14)  recommended replacing
 quarterly reporting with the requirement to produce repprts when
 requested, with an  adequate lead time to compile the report.  The
 commenter claimed that reporting requirements are  wasteful
because it is unlikely that this information will be analyzed by
 either EPA or the States.
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     Response:   When this subpart was proposed,  the General
Provisions contained in Subpart A were also a proposal,  and
required quarterly reporting.  The provisions of Subpart A are
now final and require in § 63.10(e)(3) the submission of
semiannual reports of excess emissions and continuous monitoring
systems performance.  Quarterly reports are only required if
exceedances have occurred, or if the Administrator requires more
frequent reporting to determine a source's compliance status.
The EPA does not believe that semiannual reporting is
unreasonable; this reporting frequency has been determined to be
the minimum necessary to ascertain the compliance status of a
source.
2.11   INTERACTION OF THE MAGNETIC  TAPE NESHAP WITH THE GENERAL
       PROVISIONS
      Comment:   One  commenter (IV-D-4) stated that unless the
compliance period is increased,  the  General  Provisions  compliance
extension deadlines  [§  63.6(i)(4)(i)(A)  and  (B)] should be
decreased to 6  months.   This would allow sources to  evaluate  the
impacts  of the  NESHAP  and the  controls  that  are required before
requesting compliance  extensions.
      The commenter  also suggested that  CEM's should only be
required on  the exhaust from each affected source's  control
device contrary to  the requirements  of  § 63.8(b)(2)  of the
General Provisions.   Unless the promulgated rule allows equipment
vented to a  common control device to be considered a single
 affected source,  EPA should not required CEM's on the exhaust of
 each affected source.
      The commenter recommended that EPA require one startup,
 shutdown, and malfunction plan for an entire facility, not for
 each affected source  (§ 63.6 of the General Provisions).   The
 General Provisions require a startup, shutdown, and malfunction
 plan for each affected source; as "affected source" is defined
 for this NESHAP, a separate plan would be required for each piece
 of mix equipment, storage tank, wash sink,  etc.
      The commenter suggested that EPA incorporate construction
 notifications  for affected  sources  into the permitting program to
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 minimize duplicative efforts.  The commenter also suggested that
 separate notifications not be required for construction or
 reconstruction of an affected source that is not a major source
 (§ 63.5 of the General Provisions).
      In general,  the commenter recommended that EPA review the
 proposed standard for conformity with the General Provisions and
 modify the standard accordingly.
      Response;   The final  rule contains Table 1,  which clarifies
 the applicability of the General  Provisions (Subpart A)  to owners
 or operators  subject to Subpart EE.   In general,  the majority of
 the provisions  of Subpart  A apply to owners or operators subject
 to Subpart EE.   Some exceptions include provisions that  pertain
 to opacity standards and associated  monitoring and provisions
 pertaining to startup and  shutdown.   The emission limitations in
 Subpart EE apply  during periods of startup and shutdown  so a plan
 for dealing with  such periods is  not necessary.   Another
 exception is  one  noted by  the commenter;  Subpart  EE overrides the
 requirement in  the  General Provisions that a continuous
 monitoring system (CMS)  be installed at the effluent of  each
 affected source  [§  63.704 (c) (2) (iii)].
     As  discussed in Section 2.2  of  this  document,  the;definition
                                                       I ,
 of  affected source  has  been expanded to the entire facility.   As
 such, requirements  of  Subpart A that were  unclear because  of a
 narrow  affected source  definition are more apparent  now.   For
 example,  given the  broader affected  source definition, only  one  '
 startup,  shutdown,  malfunction  plan  is  needed  for an entire
 facility.                                       '
     Given the change  in the  compliance timeframe  for existing
 sources,  as discussed  in Section  2.7  of this document,'the
provisions  of § 63.6(i)(4)(i) are reasonable.  In  accordance  with
 this provision, owners  or  operators  of existing sources must
apply for  an extension  of  compliance within l year of the
compliance date.                                       !
     Comment;   One  commenter  (IV-D-14) stated that the^monitoring
frequency  of 15 minutes is excessive and should be replaced by a
frequency of no more than  60 minute intervals.  The  commenter
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argued that for fluidized carbon adsorption units 15 minute
intervals is excessive, wasteful, and detrimental to good data
quality control procedures.  Because of the consistency of
emissions from a fluidized carbon adsorption system a monitoring
frequency of 60 minutes is appropriate.
     Response:  The EPA selected 15 minute averages for sources
conducting monitoring under this subpart because it is consistent
with the General Provisions and the NSPS for this industry.  The
EPA believes that this consistency is important because many
sources will be subject to the NSPS as well as this subpart.  The
EPA does not think that 15 minute averages is excessive, nor
should it compromise data quality control.  Therefore, the
requirement is unchanged.
2.12  OVERLAP OF MAGNETIC TAPE NESHAP WITH OTHER STANDARDS AND
      SOURCE CATEGORIES
     Comment:  Two commenters  (IV-D-1, IV-D-7) advised EPA to
discuss in the regulation the overlap between the proposed
standards and the NSPS for Magnetic Tape Coating Facilities
 (40 CFR 60.710-718).  One commenter  (IV-D-1) questioned if the
NSPS has any effect on the applicability of Subpart EE or a
company's compliance status under Subpart EE.  The other
commenter  (IV-D-7) requested that EPA  indicate whether the NESHAP
applies to a facility that is in compliance with the  NSPS.
     Response:  According to the General Provisions § 63.1(a)(3),
no emission standard or other requirement established under
Part 63 is to be  interpreted as  diminishing or replacing
requirements of a more stringent emission limitation  or other
requirement established by the Administrator  (including
requirements of Part 60) or requirements of a standard  issued
under State authority.  Thus, two or more emission standards or
other requirements may be  applicable to an affected source.  The
more stringent requirement takes precedence.
     Comment:  One commenter  (IV-D-9)  requested  that  when more
than one MACT  standard can apply to  a  source, EPA should  include
specific language to indicate which  standard  takes precedence  for
 the source.   For  example,  wash  sinks may also be subject  to  the
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halogenated solvent cold cleaners MACT standard; thus, two
conflicting standards could apply to the same source.
     Another coiranenter  (IV-D-13) brought this same example to
EPA's attention.  The commenter suggested that EPA exclude wash
sinks that may also meet the definition of "solvent cleaning
machine" under the proposed MACT rule for halogenated solvent
cleaning  (58 FR 62589), to avoid duplicative regulation for wash
sinks that use halogenated solvents.
     Response;  As noted in the previous response, the General
Provisions provide for circumstances of overlapping regulations
on an affected source.  However, in this case exempting wash
sinks that are also regulated under Subpart T--National Emission
Standards for Halogenated Solvent Cleaning from Subpart EE is
reasonable.  Subpart T requirements are more stringent than
requirements in Subpart EE for wash sinks (solvent cleaning
machines) that use any blend of halogenated solvent as a cleaning
solvent.  This exemption easily addresses any possible confusion
on the part of owners or operators and States concerning
applicable requirements for one emission source at magnetic tape
manufacturing facilities.                             ;
     Comment:  One commenter (IV-D-13)  believed that their
facility would be more appropriately regulated under the paper
and other webs source category than the magnetic tape source
category even though they manufacture a product that contains
magnetic particles.  This commenter discussed their rationale and
provided EPA with two methods that could be used to distinguish
between the two source categories for their facility.
     The commenter stated that EPA should ensure that the
magnetic tape NESHAP does not overlap with other source
categories.  The commenter believed the broad definition of
magnetic tape will encompass operations that should be a part of
paper and other webs source category, which are different source
categories with different promulgation deadlines developed under
EPA's Source Category Ranking System.  Also,  the commenter stated
that MACT determinations must be made separately for each
category.  Because EPA has not made a MACT floor determination
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for paper and other webs,  it does not have the authority to
regulate paper and other webs under the magnetic tape source
category.  Finally, the commenter argued that by including
facilities in a source category that does not represent the
primary use of that facility, EPA is forcing control requirements
that were not based on other "peer" facilities; Congress intended
controls to be based on the best-controlled similar sources.
     The commenter suggested that EPA use primary product
rationale to distinguish between magnetic tape and paper and
other web source categories.  Primary product criteria may be
used to  determine  the source category applicable to equipment
that is  used for multiple products. The  commenter suggested that
the primary product be defined as the product with greatest
actual  square  footage of product  coated  when  compared  to  total
product  coated on  an annual  basis.   If more than one product were
considered primary and at least  one of  these  met the definition
of magnetic  tape  then the operation would be  subject to the
magnetic tape  rule.  The  commenter  noted that only  1 percent of
 its  annual production  in  square  feet in 1993  would  meet the
 definition of  magnetic  tape,  thereby triggering requirements of
 Subpart EE.
      The commenter alternatively suggested that EPA change the
 definition of magnetic tape to be based on the percent of solids
 in the coating mix (magnetic particle density in the coating
 mix),  to distinguish between source categories.  The commenter
 suggested changing the definition of magnetic tape to exclude
 products with a coating mix containing less than 10 percent
 magnetic particles by weight, to distinguish between source
 categories by the products produced.
      Response:  The Agency has addressed in Section 2.3.3 the
 question of regulating nonmagnetic products under Subpart EE.
 The Agency has considered the request made by the commenter and
 agrees.that a primary product distinction should be made  in some
 cases  to avoid including coating lines  in the magnetic tape
 NESHAP  that have  such a small amount of magnetic tape production
 that  it is more appropriate to  regulate them exclusively under
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 Paper and Other Web Coatings, rather than Subpart EE.   If
 1 percent or less of a magnetic tape product is coated;on a
 coating line,  based on the annual square footage of all products
 produced on that line, then the line is not subject to
 Subpart EE.  A cutoff of l percent,  rather than a higher
                                                       I
 percentage number,  was selected to minimize potentially
 uncontrolled emissions from magnetic tape production on a coating
 line that would otherwise be regulated under the paper!and other
 webs source category.
      The definition of magnetic tape was not changed due to the
 uncertain nature of product development.  The percent  composition
 of magnetic particles may change with the development  of new
 magnetic tape  products and a change  in the definition  of magnetic
 tape might limit the effectiveness of Subpart EE to control
 emissions from magnetic tape manufacturing in the future.
 2.13  WORDING  OF THE STANDARD
      Comment;   One  commenter (IV-D-4)  recommended that  EPA change
 the definition of mix preparation equipment to read:   "Mix
 preparation equipment means the stationary vessels,  except for
 mills..."   The commenter explained that  portable equipment,  such
 as drums,  that are  used in mix  preparation present  difficulties
 when attempting to  install emission  control equipment for  their
 use.   Also,  portable vessels  would contain relatively small
 quantities  of  HAP,  would be kept  closed  whenever possible,  and
 would have  small  openings that  would minimize  HAP emissions.
 Finally, portable equipment is  often used during experimental
 production  of  new products and  during evaluation' of new
 manufacturing  methods,  on a temporary and intermittent basis.
      Response:   Information available to  EPA from industry
 surveys  indicates that  portable mix  equipment  is  used to a great
 extent by some  sources  in this  source category.   In fac't,  at some
 sources, greater  than 50  percent of  the tanks are portable and
 are not necessarily  smaller in  capacity than stationary vessels.
 Therefore, the  emission potential  from portable  tanks is not
negligible.  Given this information, the  final rule doe|s not
exempt portable mix  equipment from the .control requirements.
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Although these vessels may have to :be vented to the air pollution
control device in a different manner from stationary vessels, the
EPA believes that it is technically feasible.  One facility is
known to vent its portable vessels through flexible hose that
allows the vessels to remain portable.  Another alternative would
be to vent the entire mix room that contains all mix preparation
equipment.
     Comment:  Two commenters  (IV-D-1, IV-D-7) recommended adding
the phrase "with this subpart" after the word  "comply" in
§ 63.701(c)  of the proposed rule, which defines applicability of
nonmagnetic  tape operations within an affected source.
     Response:  The proposed rule stated in  §  63.701 (c) that  "the
owner or operator shall comply with the standards  in this
subpart" so  EPA is not certain what change the commenters
intended.  In any event, for the reasons discussed "in  Section 2.3
of this document, this provision is not included in the final
rule.
     Comment:  Two commenters  (IV-D-1, IV-D-7) noted that  the
first sentence in § 63.703(b)  of the proposed  rule appears
incomplete.  These commenters  stated that the  first sentence in
§ 63.703(b)(1) of the proposed rule  (requiring 95  percent  control
of emissions) is confusing, and  should be reworded as  follows:
"achieve an  overall HAP control  efficiency of  95 percent  of
gaseous  HAP  emitted from each  solvent storage  tank, piece  of mix
preparation  equipment, coating operation, waste handling  device,
condenser  vent in solvent  recovery, and  set  of equipment  for
flushing fixed lines;  or..."
     Response:  This  paragraph of  §  63.703 has been  revised, in
response to  other comments,  to clarify  that  it is  acceptable to
vent the room in which affected  sources  (such as mix preparation
equipment)  are located, as long  as compliance is  determined using
appropriate  test methods  and procedures.   The EPA believes that
the  wording  of paragraph  (c)  in .§  63.703  of  the  final rule is
 clear.
      Comment:  Two  commenters (IV-D-1,  IV-D-7) recommended
 clarifying that  in  §  63.703(b)(2)  of the proposed rule
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 (concentration limit for incinerators), the alternative
concentration limit applies only to the incinerator outlet and
that all units listed in § 63.703(b)(1) must still be controlled.
As written, it is not clear where the  20 parts per million by
volume  (ppmv) limit applies and that all affected sources at the
stationary source need to be controlled by the incinerator.
These commenters also suggested that § 63.703(b)(2) address the
situation when some affected sources are controlled by an
incinerator and other affected sources are controlled by another
type of control device.  The commenters suggested language to be
added to this section of the proposed .rule.
     Response;  The final rule clarifies that the concentration
limit must be achieved at the outlet of the incinerator, and that
the emission points identified in paragraph (c) of the final rule
need to be controlled regardless of the control technique used.
However, some emission points could be controlled by an
incinerator, and others by another control device achieving
95 percent control.  The final rule is also clear that the
concentration limit only applies when  an incinerator is used to
control an emission point, and that the incinerator can meet
either the 95 percent reduction limit  or the outlet concentration
limit of 20 ppmv.
     Comment:  Two commenters (IV-D-1, IV-D-7)  suggested adding
the phrase "no less than" in front of  "88 percent" in
§ 63.703(d)(1)  of the proposed rule  (control requirement for wash
sinks).
     Response:  This change has been incorporate'd.
     Comment;  Two commenters (IV-D-1, IV-D-7)  recommended
rewording § 63.703 (f) of the proposed  rule (control requirements
for wastewater) to state "Wastewater treatment systems.  Each
owner or operator of a wastewater treatment system that is an
affected source shall..." since the word "source" is not defined.
These commenters also noted that § 63.703(f)(1) needs an "or" or
"and" at the end, depending on whether either or both of the
options apply.
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     Response;  This provision  has  been revised and is  now in
 §  63.703(g).  The  provision states  "Each owner or operator of an
 affected  source shall  treat the wastewater discharge..."   Also,
 an "or" has been added after paragraph (g)(1)  because only one of
 the two criteria has to be met.
     Comment;  Four commenters  (IV-D-1,  IV-D-7,  IV-D-9,  IV-D-13)
 noted  that  §  63.704(b)(1)(ii) of the proposed rule,  which
 specifies the use  of a CEM to measure inlet and outlet  VOC
 concentrations to  determine compliance,  should reference
 §  63.704(c) (3) (i)  rather than § 63.704 (e) (3) (i) .
     Comment: Two  commenters (IV-D-1, IV-D-7)  suggested rewording
 the phrase  "a 99 percent removal rate" in § 63.704(b)(7)(i) of
 the proposed  rule, to  "at least a 99 percent removal rate."
     Comment:  Two commenters  (IV-D-4, IV-D-13)  noted a
 typographic error  in § 63.704(b)(6) of the proposed regulation:
 §  60.704  should be §  63.704.
     Response:  The final rule  is organized differently than the
 proposed  rule.  When the above  comments were still applicable,
'they were incorporated.  The final rule was also carefully
 checked  to  ensure  that the cross-references are correct.
     Comment:  One commenter (IV-D-9) suggested EPA include
 language  in the  definition of  "drying oven" to indicate that
 solvent  is  evaporated in this equipment.  As currently worded,
 the definition  would include cure rooms where no solvent is
 evaporated.
     Response:   This change has been incorporated.
     Comment:  One commenter (IV-D-13) recommended that relevant
 citations be added to the requirements for the initial
 performance test for enclosures  [§ 63.704(b)(5) in the proposed
 rule]  to clarify when the use  of an enclosure may be used  for a
 compliance demonstration.  The commenter assumed that the  use of
 an enclosure would be part of  a capture efficiency test in cases
 where  emissions are not routed through hard piping or ductwork to
 a control device.
      Response:   In the final rule, §  63.705(a)  states that
 initial performance testing must be done to show compliance  with
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 § 63.703 unless exempted by § 63.705(a)(1),  (2),  or (3).
 Section 63.705(a)(3)  exempts only those capture devices
 (e.g.,  rooms,  enclosures,  or hoods)  that were tested to
 demonstrate  compliance with Subpart  SSS of  Part 60,  and for which
 there are sufficient  data to establish an operating parameter
 value in accordance with § 63.704(b)(6).  All other enclosures
 must be tested following the procedures in  § 63.705 (c) ;,  (d) ,  (e) ,
 and/or (f),  as appropriate.
      Comment:   One  comment er (IV-D-9) -.noted that  equations  2,3,5,
 and 6 in § 63.705(c)  of the proposed rule contain errors.
      Response;   The commenter was  not  specific.   However, the EPA
 has reviewed the equations to ensure they are correct;, no errors
 were found.
      Comment:   One  commenter (IV-D-11)  suggested  EPA include
 Table 1 from the preamble  in §  63.703  of  the proposed rule  with a
 column added to include requirements for  each emission point
 listed in §  63.701(a)(2)  of  the proposed  rule.  The  commenter
 stated that  the table  is more straightforward than the text,  and
 that sources will more easily be able  to  determine which
 requirements are applicable  to  them.   Two commenters  (IV-D-1,
 IV-D-7)  suggested adding a table to  §  63.704 of the proposed
 rule,  which  describes  compliance and monitoring requirements,  to
 clarify the  requirements for each  type  of control  device.   The
 commenter suggested the table include  the following items:  the
 parameter to measure for initial compliance  test,  which
 site-specific operating parameters must be determined,
 operational  requirements,  parameters to monitor continuously, and
 recordkeeping requirements.
      Response:   The EPA has  added Table 1 to the final rule,
 which explains  the  applicability of the General Provisions  to
 sources  subject  to  Subpart EE.   Tables summarizing the standards
 and  compliance monitoring  for specific capture and control
 techniques are not  included  because of potential discrepancies
between  the  tables  and  the regulatory text.   Summary tables are
provided  in  the promulgation preamble.
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     Comment:   One commenter (IV-D-13)  suggested that EPA change
the definition of capture efficiency so that it is limited to
HAP.  According to the commenter, flexibility of measuring total
organics is allowed by the definition;  however, MACT only
regulates HAP and the definition of one of the two factors used
to calculate overall HAP removal efficiency  (a measure of
compliance) must reflect that only HAP are regulated and still
allow the owner or operator to elect to measure non-HAP as well.
The commenter suggested an alternate definition to reflect that
only HAP are regulated.
     Response:  The EPA believes that the definition of capture
efficiency that is included in § 63.702 is appropriate; the fact
that it is in terms of pollutants in general and not just HAP
does not change the fact that only HAP compounds need be captured
to  comply with this subpart.  In § 63.705(c)(2)(ii) and
 (c)(3)(ii) it is clearly stated that capture efficiency is
determined by capturing, venting, and measuring all HAP
emissions.  Thus, only HAP are regulated.  Likewise, paragraph
 (c)(4)  of the same section discusses capture efficiency of a
total enclosure in terms of HAP  emissions only.
     Comment:  One commenter  (IV-D-13) recommended changing the
term  "magnetic tape manufacturing operation" to  "magnetic tape
coating operation."   The commenter believed the  term manufacture
could be  interpreted  too broadly to include  the manufacture of
the base  substrate to which  coatings are  applied.  The  substrate
may be  included  in other source  categories  such  as "polymers  and
other  resins" and would not  be appropriate  to  include  in  this
source  category.  By  listing the emission points  associated with
 coating operations,  it would be  made  clear  that  coating as well
 as related emission points  are  included  in  the applicability of
 this  rule.
      Response:   The  term magnetic  tape manufacturing operation
 has not been changed in  the final  rule.   The EPA thinks that  the
 definition is clear  that  the emission points to be regulated are
 those associated with magnetic  tape only.  The term magnetic tape
 coating operation could suggest that  emission points such as
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 solvent  storage, waste  handling,  cleaning,  etc.  are  not  covered
 by  this  subpart.                                       |
      Comment:   One  commenter  (IV-D-13)  stated  that in  the
 compliance and  monitoring  requirements  [§  63.704(e)  of the
 proposed rule], the term "solvent recovery device" is  too broad.
 The commenter suggested that  EPA  clarify its meaning,  as it  could
 be  confused with solvent distillation/purification operations.
 If  referring to carbon  adsorption system or condenser, these
 terms should be used instead  of "solvent recovery device."
      Response;  The final  rule contains a  definition of  solvent
 recovery device.  For the  purposes of this  rule, a solvent
 recovery device is  an air  pollution control device that  collects
 rather than destroys HAP solvent  in an  exhaust stream.   The  HAP
 solvent  may be  purified and reused on site, or may be  shipped
 offsite.  Examples  of such devices are  carbon adsorption systems
 and condensers.                                        '
      Comment:   One  commenter  (IV-D-13)  suggested EPA change
 "following manufacturer's  specifications"  to "following
 manufacturer's  specifications or  other written procedure" in the
 demonstration of compliance for an enclosed transfer device
 [§  63.705(g) of the proposed  rule],  to allow installation and
 operation of enclosed transfer devices that have been  developed
 in-house or modified to suit  the  needs of  the operation.
      Response;  This  comment has  been incorporated.
 2.14  MISCELLANEOUS
 2.14.1   Alternative Compliance Plans
      Comment;   Four commenters (IV-D-4 and  IV-F-'l Tacconi,
 IV-D-13,  IV-D-16, IV-D-ll) made remarks on  inclusion in  the  rule
 of  provisions for emissions averaging.  The first commenter
 stated that controlling emissions  from solvent storage tanks with
 the same primary control device used to control  other emissions
 at  a  facility would not  be cost effective.  The  commenter noted
 that  storage tanks  may  be  located  a considerable distance from
 the main facility for safety and  insurance  reasons and
 controlling the low level  of emissions from storage  tanks would
not be cost effective given the amount of ductwork that would be
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required to connect them to the primary control device.   The
commenter also stated that compliance with the regulation through
control of storage tanks with a dedicated small carbon canister
would be very difficult and extremely expensive particularly if
installation of a GEM on the carbon canister is necessary.  The
commenter believes that allowing emission averaging in the
standard would alleviate these difficulties by not requiring
emission control and CEM on all emission units.  The commenter
notes that drawbacks of emissions averaging regarding weighting
factors would not be an issue in this industry, because the
solvent HAP used in the industry all have the same weighting
factor.   (The commenter did not specify what kinds of weighting
factors he was referred to.)  Also, emissions averaging would
alleviate logistical difficulties associated with implementing
the standard by not requiring CEM's on all sources.  The
commenter suggested the following text be added to the regulation
as §  63.701(d)(10) of  the proposed rule  (affected sources):   "As
an alternative, each magnetic tape manufacturing operation  may
group any number of affected sources listed in  § 63.701(d)  to be
considered as a single affected source for the purposes  of
emission averaging or  compliance with the General Provisions."
The commenter submitted additional comments that addressed  the
impacts  on emissions averaging  and interaction with  the  General
Provisions.
      The  commenter also  suggested  creating a  simplified  version
of  the emissions  trading  scheme included in the Hazardous Organic
NESHAP (HON)  (59  FR  19402).  The  commenter stated  that EPA  could
disallow trading  between HAP of varying  risk  factors and require
a slight excess  HAP  reduction  of  10  percent to overcompensate for
any measurement  inaccuracies.   The EPA could  also  eliminate any
 requirement that  a facility conduct  any air emission monitoring,
modeling,  and risk assessment  since  no trades between HAP of
 different risk factors would be allowed.
      The commenter also suggested that EPA eliminate the
 restriction that HAP emission reductions above the control device
 reference technology control level are not allowed in emission
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 trading.   The commenter stated that a facility will normally
 operate its control device at a level above the compliance limit
 to ensure compliance,  even though this practice results in higher
 operating costs.   The  commenter maintained that because this
 additional control is  usually achieved solely for compliance
 reasons,  it should be  allowed to be included in emissions
 averaging calculations.
      The  second commenter (IV-D-13)  suggested a prioritization
 scheme that evaluates  the relative contribution of each
 individual source relative to the total emissions from the entire
 magnetic  tape operation.   According to the commenter,
 prioritization would allow cost effective  control and  would
 exempt sources that in the aggregate contribute less than  or
 equal to  5 percent of  the total emissions.   The commenter
 suggested this method  should be offered as an alternative  to the
 de minimis levels they had proposed.   According to the commenter,
 prioritization would provide flexibility and reduce paperwork
 burden associated with compliance demonstrations on sources that
 contribute little to the  total  emissions in the industry.   They
 suggested including the following language as § 63.703(b)(3)  of
 the proposed  regulation:   "In lieu of  the  requirements:of
 §  63.703(b)(1)  and (2), the  owner or operator may elect  to
 identify  sources  that  represent at least 95  percent of:the total
 actual  annual  HAP emissions  from the  sources subject to  this
 subpart and achieve an overall  HAP removal  efficiency  of
 95 percent  from these  identified sources.   Sources, which  in  the
 aggregate  contribute five  or less  percent  of the'total emissions
 from  the  source subject to this subpart  are  not  subject  to the
 control requirements of this  subpart."
      The  commenter  suggested  as  an alternative  a very similar
 plan  allowing  emissions averaging  such that  some  sources may be
 over  controlled while  other  sources are  undercontrplled to
 achieve 95 percent  control of emissions  from the entire
 operation.
     The third commenter  (IV-D-16) stated that  the  definition of
affected source is  overly  restrictive and that a broader
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definition of affected source would provide flexibility and allow
emissions averaging.  The coiranenter provided an example of
averaging emissions from an entire mix/coat operation so that
more efficient emissions control achieved from the coating line
(generally greater than 95 percent) can offset less efficient
control of the VOC-dilute mix room exhaust (generally less than
90 percent).  The commenter suggested that a group of emission
points collocated and ducted to a common abatement device within
a facility (e.g., all mix room equipment, or coating operations)
be treated as a single affected source.  The commenter argued
that under this approach environmental protection will be equal
to if not greater than with the narrower definition of affected
source and domestic producers would not be further disadvantaged
by the burden of regulatory costs.
     The fourth commenter  (IV-D-11) recommended that EPA not
consider emissions averaging any further.  The commenter stated
that emissions averaging most often results in increased
emissions of toxic chemicals that are more difficult to control
and may include HAP.  Also, emissions averaging programs have
been difficult to enforce and to administer, with burdensome
compliance and recordkeeping requirements.
     Response:  The prioritization scheme suggested by one of  the
commenters would achieve less control than the main standard
because it would exempt 5 percent  of the uncontrolled emissions,
and only require 95 percent control of the nonexempted emissions.
Furthermore, this plan would not account for the fact that the
underlying standard is not 95 percent control for all emission
points.  Therefore, it was not  considered further by the  EPA.
     Several of  the comments on emissions averaging for magnetic
tape manufacturing  appear  to be concerns about compliance
demonstrations,  rather than a need for emissions averaging.   For
example, a  commenter  suggested  that all  emission sources  vented
to the same  control device be allowed to be  "averaged"  so that
only the common  control device  has to be monitored  (such  as  the
tanks  in the mix room and  the coating operations).   It  is the
EPA's  intent that when several  sources are vented  to a  common
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control, the control device itself is monitored; each emission
point does not have to be monitored separately.  This point has
been clarified in the final regulation.
     This commenter also alluded to the problem for the primary
control device of achieving 95-percent control when the coating
operations are not occurring because the other streams vented to
the device have low flow rates and low concentrations.  The EPA
has included in the final rule an alternative standard in which
the owner or operator would determine, during a period when the
control device is properly operated and maintained, a
concentration level for the control device when the coating
operations are not operating.
     Another commenter expressed concern that the proposed
regulation would have required continuous emission monitors
(CEM's) on carbon canisters, which might be used to control
storage tanks far from the main control device.  The EPA
recognizes that the proposed rule had not adequately considered
monitoring for such situations and is including alternative
monitoring for nonregenerative carbon adsorbers in the final
rule.
     One particular problem area that was mentioned in other
comments as well as in those on emissions averaging was the
control of storage tanks.  Commenters noted that emissions from
storage tanks are small and may be cost ineffective to control in
                                                      i
comparison with other control costs imposed by this rule.  This
could be true particularly for those that are sited away from the
main coating operation (hence the primary control device) for
safety or insurance reasons.  As discussed in Section 2.6.2 of
this document,  based on available information, there is no basis
for subcategorizing among storage tanks based on size or distance
from the control device.    However,  the EPA agrees that storage
tanks could be cost ineffective to control if far from the main
control device,  and that the emissions are small.   The estimated
uncontrolled HAP emissions from all the storage tanks at a small
facility total 0.01 ton/yr and at a large facility total 1.2
tons/yr.                                              i
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      To meet this concern,  the EPA developed an alternative
. compliance option that would allow the owner or operator not to
 control certain storage tanks in return for achieving more
 control of the largest emissions source at magnetic tape
 manufacturing facilities.  Under this option, in exchange for
 accepting a requirement of 97 percent reduction (instead of
 95 percent as required by the basic standard) for all the coating
 operations, the owner or operator may leave uncontrolled up to
 10 storage tanks with a maximum individual capacity of
 20,000 gallons.  There are also two additional tiers: to control
 all  coating operations by 98 percent in lieu of controlling
 15 such storage  tanks; or 99 percent in lieu of controlling
 20 such storage  tanks.  Available  information  indicates  that  this
 range  of  options is  adequate  to cover the  range of plants.
      This alternative  compliance  option might  appear  at  first to
 be inconsistent  with provisions of the HON (which is  the first
 MACT standard that provides  for emissions  averaging)  in that  the
 HON  does  not  permit  a  plant  operator to gain averaging  credit for
 using  reference  control  technology (the technology assumed in the
 development of the standard)  at a higher-than-required  percentage
  reduction.  However, there are clear factual differences which
  distinguish the two situations.                       .
       Emission limitations under the HON are applicable  to
  emission points whose characteristics equal or exceed specified
  cut-offs, and are premised on the use of  reference control
  technology.  Emissions averaging under the HON responds to
  concern  that it may be unusually expensive to apply  reference
  controls to some  of the covered emission points  (such as emission
  points located far  from a control device).  The HON  emissions
  averaging provisions allow a plant operator to avoid control  of
  some  covered emission points  (a)  by applying  the reference
  control  technology  to exempt emission points  (points whose
  characteristics are below the cut-offs) or  (b) by applying
  controls that are inherently more effective than the reference
  control  technology  to other  covered emission  points.  Except for
  reductions achieved by  pollution prevention measures,  the
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 substituted controls must produce at least  110  percent  of  the
 emission reductions  that would have been achieved at  the emission
 points  that will  no  longer be controlled.   In addition, the
 permitting authority must conclude that  risk or hazard  is  not
 increased by the  averaging.
     As stated above,  the HON does not permit the plant operator
 to  gain averaging credit for using the reference technology at a.
 higher-than-required percentage reduction.   Credits for operating
 a control technology better than its rated  control efficiency are
 not allowed for two  main reasons.   One is the fact that in the
 development of the standard,  the rated efficiency of  the
 reference technology was set on a lowest-common-denominator
 basis.   Due to the variable  nature of the pollutant streams
 encountered among plants subject to the  HON (variations from
 plant to plant in the  mix of pollutants, operating rates,  and
 other factors), the  selection of a single percentage  reduction
 applicable  to  each control  technology in all  circumstances
 required a  lowest-common-denominator approach,  and in many cases
 such equipment will  achieve  substantially higher  percentage
 reductions  under  normal  design and operating  conditions.   If
 credit  were allowed  for  this  differential,  a  plant, operator might
 gain an undeserved windfall  due  to the manner in  which :the rated
 control  efficiencies were derived.
     In the case  of magnetic  tape  manufacturing,  the  EPA is
 considering a  much simpler situation than in  the  HON.  Magnetic
 tape facilities have generally smaller variability in the plant-
 to-plant mix of pollutants,  operating rates and other factors.
 Rather  than including  any emission point as in the HON,  only two
 types of  emissions points are  eligible for the alternative
 compliance  plan for magnetic  tape  operations:  the coating
 operations  and the storage tanks.  Because of the simpler nature
 of magnetic tape processes and the magnitude  of the additional
 emissions control, EPA concludes that the emissions from the
uncontrolled storage tanks are adequately offset by additional
 control at  the coating operations.  The required two percent
additional  increase in control efficiency at the largest emission
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point at magnetic tape manufacturing plants creates additional
emissions reductions of as much as 0.35 ton/yr at a small
facility and 190 tons/yr at a large facility.  Under the
alternative compliance option, some storage tanks may remain
uncontrolled.  However, the emissions from these points are very
small in comparison to the additional potential emission benefit
accruing from the coating operations.  At small plants,
0.01 ton/yr remain uncontrolled; at larger plants, 1.2 tons.  As
in the HON, there is variability in operating conditions and
pollutant streams.  Thus, EPA is unable to quantify precisely how
much additional emissions benefit can be attributed to the
required increase in control  efficiency.  The EPA  is confident
that the emissions  from the uncontrolled points are adequately
offset by additional reductions.
     The other  reason  the HON does not allow credit for  operating
a device greater than  its reference  control  efficiency is a
concern over  enforcement problems.   The variable mix of
pollutants  and  operating  conditions  seen at  HON  sources  means
that the amount by  which  emission reductions exceed rated levels
is  difficult  to determine reliably.   The data  tracking for  each
point  and  device would be extremely  complex.  Use  of a reference
control  efficiency  for each reference control  technology allows
the implementing  agency  inspectors to check that the equipment is
 in  place and operating as planned.   Then the implementing agency
 can check records  to examine the calculation of  debits and
 credits on each of  the emission points in order to make a
                                                •* ^
 compliance determination.
      The alternative compliance approach discussed above for
 magnetic tape manufacturing would not pose these same enforcement
 problems.   The required control efficiency for the coating
 operations would be the same for all plants taking advantage of
 this approach.  Continuous monitoring for the purposes of
 determining ongoing compliance with the emission standard  is
 required.  For carbon adsorbers, the most common control device
 in the industry, GEM's are required.  (Note that CEM's are not
 required for nonregenerative carbon adsorbers, as discussed
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 above.  Such adsorbers would not be used on coating operations.)
 For incinerators and condensers, the owner or operator would be
 required to determine during the initial performance test a
 temperature that corresponds to at least 97 percent control
 (instead of the 95 percent control of coating operations required
 by the basic standard).   Therefore, the additional emission
 reduction would be ensured.
                                                       I
      In summary, the EPA believes that it can address the
 commenters' main concerns without a general emissions averaging
 scheme,  such as in the  HON.  The clarifications and changes in
 compliance determinations discussed above and the alternative
 compliance option for storage tanks and coating operations are
 sufficient.  Furthermore,  the EPA believes that,  under these
 circumstances,  permitting credit for operating a control device
 better than its rated control efficiency for the alternative
 compliance option for the magnetic tape industry is
 distinguishable from the  HON and justifiable.
 2.14.2  Other Miscellaneous Issues
      Comment:   Two commenters (IV-D-l,  IV-D-7)  suggested using
 single subscripts instead of double subscripts in § 63,702(b)  of
 the proposed rule.   The commenters stated that the double
 subscripts  were confusing.
      Response;   The purpose of using double  subscripts  in
 §  63.702(b)  is  to conform with the nomenclature used in  the
 NSPS  for magnetic tape coating facilities  (40  CFR 60,  '•
 Subpart SSS).   The  Agency  believes  that using  the same
 nomenclature in the NESHAP as is used in  the NSPS will reduce
 confusion because the majority of  owners and operators of sources
 affected by this  rule are  already  familiar with the NSPS  for
 magnetic tape coating facilities.                      i
     Comment;   One  commenter  (IV-D-5) suggested that tlie  rule be
 promulgated by  November 15, 1994, stating that promulgation of
 the standard on schedule is important for the States, which must
 implement and enforce the  standards.
     Response:  The  final rule will be promulgated by  |
November 23, 1994 in accordance with a consent decree reached
                              2-84

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between the Sierra Club and EPA (Sierra Club vs. Browner,  Case
No. 93-1024 [and related cases][DC District Court]).
     Comment:   One commenter (IV-D-9)  stated that EPA should
include incentives for pollution prevention activities that occur
after the effective date of the rule.   The commenter suggested
incentives such as reduced recordkeeping and reporting
requirements for voluntary reductions, which has been done in
other standards and programs.
     Response:  An incentive for pollution prevention activities
has been incorporated in the standard.  The term utilize has been
revised to consider net usage to further encourage pollution
prevention measures, and a provision has been added to allow an ,
equivalent low-HAP coating limit to encourage the development of
low-HAP coatings.
     Comment:   One commenter (IV-D-11) stated that omitting the
regulatory text from the Federal Register notice is not good
policy.  The commenter reasoned that interested persons should
have easy access to the regulatory text; requesting a copy from
EPA through the mail takes time out of the comment period, and
downloading from the Technology Transfer -Network  (TTN) requires
computer equipment and expertise and ties up a computer for a
long time.  The process of downloading the regulation from TTN
could be difficult, especially for small facilities affected by
the rule.  Also, the document from TTN must be edited before
printing to condense it.  The commenter suggested that the
preamble should be omitted from the Federal Register notice, if
necessary, not the regulation.  Finally, the commenter suggested
that it be made clear in the preamble that the regulatory text is
not included in the Federal Register notice by using highlighted
text.                                                           -
     Response;  The Agency has reviewed its responsibility to
adequately inform the affected public of proposed actions.  The
decision to reduce the amount of printed material in the Federal
Register and assure that the material, including the proposed
regulatory text of the proposed rule, is accessible for public
comment and judicial review does not  conflict with  the statutory
                               2-85

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requirements of the Administrative Procedures Act  (APA), the
Federal Register Act  (FRA), nor the requirements of the Clean Air
Act Amendments of 1990.  Access to material that is used as the
basis of the proposed rule  (officially 1'ocated in  the Air and
Radiation Docket) is identified in the preamble to the proposals
and promulgations of rules.  Specifically, the Agency clearly
established and will continue to look for additional connections
along with directions to obtain the text of information not
printed in the Federal Register through the Technology Transfer
Network's bulletin board for recently signed rules, directly from
the Air and Radiation Docket and Information Center, through
distribution to trade associations, through plaintiffs, in court
ordered regulatory actions, through contact with small! business
ombudsman systems in each State, and if necessary  through the
contact person at the Agency.  The response has been positive as
the process has aged.
     The Agency believes that all information that is developed
in the course of the development of a proposed and final rule is
important, however, the need to publish information in the
Federal Register must be addressed realistically and responsibly.
The Agency will continue to review its extensive publishing in
the Federal Register with its responsibility to adequabely inform
affected parties of our proposed and final actions.
     Comment:  One commenter (IV-D-12) stated that the; draft
environmental impact statement  (EIS) does not address issues of
employee safety, exposure, and health.  The commenter noted that
several HAP listed in the EIS have occupational health1 criteria
which have to be met by companies under the Occupational Safety
and Health (OSHA) limits for air contaminants.  Also, methyl
ethyl ketone (MEK), methyl isobutyl ketone (MIBK), and xylene
exposures are associated with central nervous systems symptoms
and irritation.  Toluene diisocyanate exposure has been connected
                                                      i
with sensitization effects, occupational asthma, and it is
considered a potential human carcinogen.  Cobalt exposure has
been associated with pulmonary fibrosis and dermatitis; exposure
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to hexavalent chromium has been connected with human respiratory
cancers.
     The commenter also noted that some of the processes and
procedures listed in Chapter 3 of the proposal BID could increase
employee exposures with no mention of measures to reduce
exposures or personal protective equipment.  These processes
include pouring solvent by hand, cleaning pieces by hand, and
spraying open-top tanks with solvents to clean them.
     In addition, the commenter noted that Chapter 4 of the
proposal BID has no reference to employee safety or exposures
when performing routine maintenance on emission control devices.
For example, the commenter noted that carbon adsorption systems
are known to be susceptible to  fire.
     The commenter also stated  that Chapter 4 of the BID does not
mention worker safety considerations with respect to plant
operations.  For example, the BID does not mention  if an employee
works  inside or outside a total enclosure, which would greatly
affect his/her exposure to HAP.  Also, drying oven  emissions can
escape into  room air and  reach  the worker.  Additionally,
Chapter 4 refers to the ventilation rates  for the control of
worker exposures on the coating line as  well as exhaust  hoods
over wash sinks, but downplays  their importance since these
controls are not very  effective in  controlling HAP  to the
necessary levels  for air  pollution  control.   Chapter 4  also
suggests  the substitution of  non-HAP solvents  for the ones
currently in use,  but  there  is  no mention of  the  toxicity of the
substituted solvents  in  terms of  employee exposures.  Finally,
Chapter 6 discusses model lines for HAP  without mentioning
employee  exposure or  controls necessary  to protect  workers.
      Response:   The Agency recognizes  that there  may be
 significant health risks associated with worker exposure to the
HAP that  are regulated under this rule.   However, because OSHA
 has jurisdiction over regulating the work environment,  the
Agency's  policy has  been to address only the health effects and
 risk associated with pollutant emissions to the ambient air.   The
 EPA does not believe that any of the MACT requirements would
                                2-87

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 increase worker exposure to HAP, but would decrease their
 exposure.  For example, all mix tanks are required to 'be covered
 and vented to control, and HAP particulate transfer operations
 are also regulated.                                   :
 2.15  PERFORMANCE SPECIFICATIONS
      The following comments were received upon proposal of the
 Enhanced Monitoring Regulations, proposed for inclusion in 40 CFR
 Part 64, (58 FR 54648, October 22,  1993), for Performance
 Specifications 101 and 102 (PS 101  and PS 102).   The PS 101 and
 PS 102 will be promulgated as Performance Specification 8 and 9
 (PS 8 and PS 9)  respectively,  40 CFR Part 60,  Appendix B.
 Comments addressed to the docket (Docket No.  A-91-52)  for PS 101
 and PS 102 will  hereafter be addressed as PS  8 and PS 9,  for the
 sake of clarity.   The list of commenters for  PS  8 is provided in
 Table 2-2.   The  list of commenters  for PS 9 is provided in
 Table 2-3.                                             !
 2.15.1  Performance Specification 8
      Comment;  A State agency (IV-D-283)  recommended adding a
 reporting requirement to Performance Specification 101.
 Performance Specification 102  in Part 64 and  the performance
 specifications in Appendix B  of  Part 60  all require reporting.
 Another State  agency (IV-D-438)  recommended requiring  initial and
 annual relative accuracy test  audits for VOC  CEMS in addition to
 calibration error,  response time, and performance audit tests.
 Although performing relative accuracy test audits would involve
 comparison  against a similar instrument,  that  is true  of  most
 relative accuracy test audits  for CEMS where instrumental test
 methods  are now the most commonly used.                i
     Another commenter (IV-D-339) recommended withdrawing
 Performance Specification 101  to allow additional  comments.   The
 methods  in  Performance Specification 101  are new and have been
 proposed for the  first time.   The short  comment  period did not
 allow  detailed analysis  of  the proposed methods.       \
     Response:  Performance specification 8 has  been revised  to
                                                       i
be consistent  with other performance  specifications in ^Appendix B
 to Part  60.  The definitions,  installation and measurement
                               2-88                     i

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           LIST OF ALL PS  101  COMMENTERS
I
Comment er 	 . 	 . 	
Air Compliance Total Services (ACTS)
American Automobile Manufacturers Association
Amoco Corporation 	 	 —
Bay Area Air Quality Management District
Center for Process Analytical Chemistry
Dow Chemical Company 	 . — :
Exxon Chemical Americas
Goodyear Tire and Rubber Company, The
Koch Industries, Inc. 	
Michigan Department of Natural Resources
Ohio EPA 	
Scott Specialty Gases, Inc.
South Coast Air Quality Management District
Texas Chemical Council 	
Texas Natural Resource Conservation Commission
--- ' ' - - —
Comment No.
(IV-D-19)
(IV-D-538)
(IV-D-244)
(IV-D-402)
(IV-D-318)
(IV-D-260)
(IV-D-339)
(IV-D-292)
(IV-D-332)
(IV-D-438)
(IV-D-283)
(IV-D-236)
(IV-D-524)
(IV-D-365)
(IV-D-371)
TABLE 2-3.  LIST OF ALL PS 102 COMMENTERS
Comment er 	 	 	 . 	
Amoco Corporation
Bay Area Air Quality Management District
Center for Process Analytical Chemistry
Dow Chemical Company 	 	 	
Eli Lilly and Company
Exxon Chemical Americas
Goodyear Tire and Rubber Company, The
Koch Industries, Inc. 	
Monsanto Company .„ 	 	
Ohio EPA 	 —
R J. Reynolds Tobacco Company
South Coast Air Quality Management District
Texas Chemical Council
Comment No.
(IV-D-244)
(IV-D-402)
(IV-D-318)
(IV-D-260)
(IV-D-349)
(IV-D-339)
(IV-D-292)
(IV-D-332)
(IV-D-273)
(IV-D-283)
(IV-D-258)
(IV-D-524)
(IV-D-365)
                   2-89

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 location specifications,  test  procedures,  data  reduction
 procedures,  and reporting requirements  are all  now  the  same as
 those  in PS  2,  and will be familiar  to  those persons who have
 applied the  existing performance  specifications.
     Comment;   A commenter (IV-D-365) recommended amending
 Section 1.1.2  to allow using a "mass standard"  of the solvent as
 the  CEM calibration gas to quantify  VOC emissions.
     Response:   Nothing in PS  8 precludes  the use of mass
 standards to calibrate the CEM.   If  volume mass standards are
 appropriate  for the particular application of PS 8, then they
 should be used.                                       '
     Comment:   Two commenters  proposed  revisions to Section 3.2,
 which  discusses  the stratification test procedure.  One commenter
 (IV-D-538) recommended specifying that  alternate stratification
 test methods achieving the same purpose may be allowed,  such as a
 piccolo probe  that permits sampling  of  emissions at several
 points  simultaneously.  Another commenter  (IV-D-339) recommended
 exempting combustion stacks and 8-inch  and smaller pipe from the
 stratification  test and making the sample  point placement an item
 to be  specified  by the source  owner  or  operator in the enhanced
 monitoring protocol, because VOC  stratification tests are
 unnecessary  in well-mixed  combustion stacks and the tests cannot
 be performed in  small diameter pipe.  The  commenter also stated
 that the extra cost of placing CEMS  high on stacks is unnecessary
 and unjustified.                                      i
     One State agency (IV-D-283) noted  an  inconsistency between
 Section  3.2  of Performance Specification 101 and Section 3.2 of
Appendix B of Part  64 regarding whether a  stratification test is
 required for locating a VOC CEMS.  The  commenter recommended
 clarifying whether  a stratification  test is required and pointed
 out that if  the  test is performed, the  rule does not require
 sources to report the stratification test procedure or "the test
results.  However,  this commenter questioned why a normal flow
stratification test would not be acceptable for determining the
location of a VOC CEMS.
                               2-90

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     Response:   The measurement location specifications have been
revised to be the same as PS 2.  A stratification test is not
required; if statification exists it is a problem that will
require correction if the relative accuracy requirement cannot be
met.
     Comment;  A commenter  (IV-D-260) objected to the requirement
in Section 4.1 that sources determine at least 90 percent of the
organic components in their process vent streams.  The commenter
provided proposed text requiring sources to determine all of the
organic components in the effluent stream that can reasonably be
identified using Method 18, process  chemistry, or previous
studies.  Another commenter  (IV-D-244) requested clarification of
whether Section 4.1 requires  the analyst to determine which
components constitute 90 percent of  the VOC mass of the  stream or
requires the analyst to identify 90  percent of the number  of VOC
components present.
     Response:  This requirement has been removed, and the
objective  is now accomplished by the inclusion of a relative
accuracy criteria, which  is consistent with the  other performance
specifications  in Appendix B.
     Comment:   Three  commenters (IV-D-339; IV-D-365;  IV-D-538)
objected to  the requirement in Section 4.2 that  sampling systems
maintain a temperature  above 150  degrees  Celsius.  These
commenters stated  that  150 degrees is hotter  than necessary,
would  require  significant maintenance,  and would cause mechanical
problems.   One commenter (IV-D-538)  recommended allowing the use
 of commercially available heated sampling system' alternatives
 with a range of 110 to 120 degrees Celsius.   The commenter stated
 that a temperature of 120 degrees would prevent condensation in
 sample lines and would require less maintenance.  This commenter
 recommended establishing temperature requirements for sample
 gases on a case-by-case basis according to the condensation point
 of the constituents at ambient conditions.  Another commenter
 (IV-D-365) proposed a minimum temperature of 110 degrees Celsius.
 Another commenter (IV-D-339) proposed requiring sources to
 maintain the sample above  its dew point and recommended limiting
                                2-91

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 the applicability of Section 4.2 to samples that operate above
 their dew point or to combustion stacks.  This commenter stated
 that heated sampling systems are only appropriate for hot
 samples, such as combustion stacks.
      Response;   As noted above, a sampling system heating system
 is no longer described in the method.   The necessity for one and
 how it is operated is determined in effect by the CEM'ls ability
 to achieve the  relative accuracy specification.
      Comment;   Commenters (IV-D-19; IV-D-283)  also requested that
 the final rule  clarify what is required to show the effectiveness
 of unheated VOC sampling systems as required in Section 4.2.
 One of these commenters (IV-D-19)  provided proposed teixt
 revisions that  would tie the showing of effectiveness to specific
 relative accuracy test results.
      Response:   A sampling system heating system is no longer
 described in the method.   The necessity for one  and hojv it  is
 operated is determined in effect by the CEM's  ability £o achieve
 the relative accuracy specification.
      Comment:   A commenter (IV-D-538)  recommended specifying in
 Section 4.3 that a GEMS  instrument  span must be  between 1.5  and
 2  times the level  of  the  emission  limit or be  a  span covering the
 expected emission  limit  range.   For low emission limits,  it  is
 not practical to limit  instrument  spans to two times the level of
 the emission limit.   One  State  agency  (IV-D-283)  recommended
 clarifying  "average potential emission"  in Section  4.3,  noting
 that  the  term raises  questions  about whether the  indicated span
 value would be  adequate.
     Response;  As noted above,  in  revising PS 8  to  make  it
 consistent  with PS 2, the provision of  PS  2 is now  included  that
 says the  high level calibration value must be within l.'s  times
 the pollutant concentration value corresponding to the emission
 standard  level  and the span value.  The span value is defined  as
 "The upper  limit of a gas concentration measurement  range
specified for affected source categories in the applicable
subpart of  the gegulations".  "Average potential emission level"
refers to the establishment of the high level value  only for the
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measurement of uncontrolled emissions in the absence of a
specified span value.  The looser specification for this high
level value is indicative of the difficulty of making a precise
determination of this value.
     Comment:  Certain commenters recommended modifying
Part 4.4.1 to allow gases other than high-purity air to
constitute "zero gas."  One commenter  (IV-D-19) provided proposed
text revisions adding other gases with low concentrations to the
definition of  "zero gas."  Another commenter  (IV-D-339)
recommended adding inert gas as an alternative to high-purity
air.  This commenter stated that zero  gas should specify maximum
hydrocarbon content but should not be  limited to air.
     A  State  agency  (IV-D-283) also  recommended specifying  in
Section 4.4.2  whether EPA protocol gases are  required  for
calibration purposes.
     A  few commenters recommended  revising  Section 4.4.2.1  to
account for  situations  where  it  would be  impossible to use  VOC
 components in the same  proportion  that comprises  90 percent of
 the VOC in the effluent stream.  One commenter (IV-D-538)
proposed allowing sources  to  use validated commercial  standards
 as an alternative.   This commenter noted that for applications
 with three or more components,  it  would be impossible to make up
 a properly proportioned standard.   Another commenter  (IV-D-365)  .
 recommended requiring VOC components in the same proportion
 "whenever possible."  Finally,  two commenters (IV-D-318;
 IV-D-339) stated that requiring a calibration gas representing
 90 percent of the VOC in a process stream, which" may  contain
 several hundred components, would be  infeasible, and  one of these
 commenters recommended deleting Section 4.4.2.1.
      Response;  In revising PS 8 to be consistent with PS  2,
 these  specifications concerning the calibration gases have been
 removed.  The relative accuracy specification will  determine  the
 adequacy  of  the  calibration gases.
      Comment:  A few commenters addressed  the issue of. gases  used
 in CEMS audits.  Some  commenters  (IV-D-236;  IV-D-538)  recommended
 amending Section 4.5 to allow EPA protocol gases  to be used in
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 audits of VOC CEMS instead of requiring sources to use certified
 EPA audit gases.  One of these commenters (IV-D-236) pointed out
 that EPA has a limited inventory of audit materials, and using
 protocol gases would make a wider range of gases available for
 audits.  Another commenter (IV-D-260)  recommended amending
 Section 4.5 to allow any accurate audit gas to be used,
 regardless of its source, for CEMS calibration.
      Response:   In revising PS 8 to be consistent with PS 2,
 these specifications concerning the calibration gases have been
 removed.   The relative accuracy specification will determine  the
 adequacy of the calibration gases.
      Comment:   One commenter (IV-D-260)  proposed changing the
 0.5 percent resolution requirement for instrument span in
 Section 4.6  to a resolution requirement of  1.0 percent..  The
 commenter observed that many instruments having a resolution  of
 1.0 percent of  span are in use today and generate acceptable
 results.   Purchasing new instruments to  meet a 0.5 percent
 specification would be costly and unnecessary.
      Response:   In revising PS 8  to be consistent with PS-2,  the
 resolution requirement has  been removed,  as  the other
 specifications  will be sufficient to insure  that adequate
 measurement resolution is achieved.                    i
      Comment:   Two commenters (IV-D-318;  IV-D-339)  noted  an
 inconsistency between Section 4.7,  which allows for a two-minute
 response  time,  and Section  4.10,  which sets  the analysis  update
 time  at 1 minute.   One commenter  (IV-D-339)  recommended changing
 the analysis update time  in Section 4.10  to  2 minutes.
      .Response;  A minimum response  time  is no longer specified  in
 PS 2, as  it  is  not consistent with  the other PS's  in Appendix B.
 Knowledge of the  response time  is required,  however,  to properly
 correlate the reference method and  CEMS data in the  course  of the
 determination of  relative accuracy.
      Comment:   Certain commenters  (IV-D-260; IV-D-292; IV-D-318)
 recommended  that  the Performance Specifications  require sources
 to determine calibration  error at two concentrations  (e.g., high
and low) instead  of at three  as required by  Section 4.8.   One
                               2-94

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commenter (IV-D-260)  proposed substituting the.procedure
described in Section 4.1 of Appendix C and making conforming
changes in Section 6.1.1 of PS 101 as well as Section 4.8.
Another of these commenters (IV-D-292) pointed out that two
levels of concentration is consistent with accepted good
laboratory practices.  Finally, one of the commenters  (IV-D-318)
requested that the EPA Technology Transfer and Regulatory Support
Group address this issue.
     One State agency (IV-D-283)  pointed out inconsistencies
between Section 4.8 and other sections.  Requiring CEMS to be
capable of performing a daily calibration error determination at
all three levels conflicts with the requirements of Section 2.3
of Appendix B and Section 2.1.2 of Appendix D.  Also, allowing a
5.0 percent difference between the CEMS response and calibration
gas values is less stringent than the performance specifications
in Appendix B of 40 CFR Part 60.
     A local agency  (IV-D-524) noted inconsistencies with 40 CFR
Part 75.  The allowable calibration error should be 2 percent
instead of 5 percent, and the sample reading time should be
15 minutes instead of 1 minute.
     Finally, an industry commenter  (IV-D-244) requested
explanation of the basis for the +/-5 percent figure in
Section 4.8 and asked whether the +/-5 percent figure applies to
the average of the CEMS at the three calibration levels or
applies to each GEM individually.
     Response:  In the revision of PS 8 to be consistent with
PS-2, calibration error is no longer specified. ' Calibration
drift is, however, and it must be determined at two concentration
levels.
     Comment:  A State agency  (IV-D-283) recommended changing the
relative error in Section 4.9 from 10 percent to 5 percent.
Because performance audits use a comparison to calibration gases,
which are required to be very accurate, a 5 percent relative
error would be achievable.  Another commenter  (IV-D-332)
recommended modifying the relative error specification in
Section 4.9 to cross-reference relative accuracy specifications
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in Appendices B and F of 40 CFR Part 60, because the
specification in Section 4.10 is inconsistent with generally
accepted practices.  Another commenter  (IV-D-402)  proposed
relaxing the relative error specification from 10 percent to
20 percent for emission standards with low concentrations that
are lower than applicable Federal standards.  The commenter, a
State air quality agency, provided detailed examples of standards
that it imposed that are far below federal requirements and for
which 10 percent relative error would be too stringent.
     Response:   Calibration drift is readily determined with
stable calibration gases, and the revision of PS 8 to be
consistent with PS 2 means that the specification that the drift
not exceed 2.5 percent of the span value.
     Comment:  One commenter (IV-D-371) recommended allowing GEMS
to measure at whatever frequency is specified in the appropriate
regulation or permit as required under Section 4.9 of Performance
Specification 102, instead of requiring measurement frequency to
be set at 1 minute as required in Section 4.10.        ;
                                                       I
     Response:   This comment is consistent with the removal of
this specification that ocurred with the revisions previously
mentioned.                                             [
     Comment:  A State agency (IV-D-283) recommended amending
Section 5.1 to require a conditioning period for establishing
electronic stability before conducting certification tests.
                                                       I
Performance Specification 1 in 40 CFR Part 60, Appendix B,
contains a similar requirement.  Another commenter  (IV-D-260)
recommended deleting the requirement in Sections'5.3 and 5.4 that
sources conduct response time tests and performance audits each
quarter.  This commenter argued that requiring quarterly response
time tests would conflict with Section 1.1.1, which states that
the procedures evaluate GEMS performance at the time of
installation.  The commenter continued by stating that if testing
beyond initial testing is required, annual testing would suffice
and is the norm in other specifications.
                                                       i
     Response:   The rationales for these comments are consistent
with the previously mentioned revisions.
                               2-96

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     Comment:   A State agency (IV-D-283)  recommended clarifying
Section 6.1.1 to improve the differentiation between the daily
two-point calibration tests and the three-point calibration error
test conducted during the seven-day calibration error test
period.  The commenter recommended calling the three-point test a
"linearity test," which would be similar to language used in
40 CFR Part 75.
     The same agency noted that the method of calculation
specified in Section 6.1.2 does not agree with the performance
specification criteria in Section 4.8.  The commenter recommended
differentiating the methods of calculation for the daily two-
level calibration error test and the three-level calibration
error test.  Finally, the agency recommended specifying in
Sections 6.3.1 and 6.3.2 how many times audit gases are to be
introduced into the sampling system and when audit readings
should be taken.
     Response:  As described in previous responses, the
calibration error determination has been replaced by the
calibration drift determination, which is made at two
concentration values, not three.
2.15.2  Performance Specification 9
     Comment:  A commenter  (IV-D-339) recommended withdrawing
Performance Specification 102 to allow additional comments.  The
methods in  Performance  Specification  102 are new and have been
proposed for  the first  time.  The short  comment period  did not
allow  detailed analysis of  the proposed  methods.  Another
commenter  (IV-D-273)  requested clarification of "the applicability
of  Performance Specification 102, stating  that gas
chromatographic  CEM's should only be  used  for volatile  compounds
and not  for semivolatile compounds.   Also,  gas chromatographic
CEM's  should not be  used in saturated gas  streams  or  in gas
streams  where aerosols  may be present.
     Some  commenters (IV-D-244;  IV-D-258;  IV-D-260;  IV-D-318)
recommended deleting the statement  in Section 1.1  that  gas
chromatographic  CEM's may not be suitable  for applications  where
more than  five VOC components are  to  be  monitored.   Two of  these
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 commenters  (IV-D-260; IV-D-318) stated that gas chromatography is
 developing so that more than five components will be able to be
 monitored.  One commenter  (IV-D-318) requested that the EPA
 Technology Transfer and Regulatory Support Group address the
 issue of the number of VOC components that a gas chromatographic
 GEM can monitor.  Finally, one of these commenters (IV-D-258)
 stated that the number of VOC components is best determined by
 the calibration precision and linearity performance audit and
 other tests provided in Performance Specification 102 and
 included an example gas chromatogram including nine VOC
 components,  each having an accuracy and precision greater than
 98 percent.
      Response:   The EPA believes that an adequate comment period
 has been provided.   The PS 9  was originally proposed as PS 102 on
 October 22,  1993,  for inclusion in 40 CFR Part 64.   The original
 comment period  was  December 30,  1993.  Upon request from the
 public,  the  comment period was  then extended to January 31,  1994.
      The EPA agrees with the  commenters that PS 9  should not
 limit the number of compounds monitored by the source.   The
 quality assurance procedures  in PS 9  allow the source  to
 demonstrate  precision and accuracy for  the system  and  phus will
 pinpoint any problems  with the  resolution and integration of
 analyte  peaks.   That  statement  has been removed from the PS  9.
      Comment;  Many commenters  (IV-D-244;  IV-D-258; IV-D-260;
 IV-D-318;  IV-D-349;  IV-D-365) opposed the  requirement  in
 Section  2.1  that gas  chromatographs be  temperature programmable.
 One commenter (IV-D-258) noted that temperature programmability
 is not necessary in every  instance, and that Section 5.1
 indicates  that temperature programmability  is only one | of several
 ways  to  obtain adequate peak resolution while preparing  for
 testing.  Also,  if the measurement meets the standards of
precision and accuracy in Appendix A, temperature programmability
should not be mandated.  This commenter also stated that the
requirement will restrict technological innovation.  Another
commenter  (IV-D-260) stated that achieving other data quality
objectives is sufficient.  Two commenters  (IV-D-260; IV-D-349)
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discussed the cost differences between temperature programmable
and nontemperature programmable gas chromatographs.   Finally,  one
commenter (IV-D-318)  requested that the EPA Technology Transfer
and Regulatory Support Group address this issue.
     One commenter (IV-D-260) proposed changing the definition of
"calibration precision" in Section 2.2 to the error between
triplicate injections of each calibration standard,  instead of
the agreement between triplicate injections of each calibration
standard.  A commenter  (IV-D-258) also recommended amending
Section 2.1.1 to allow more  than one chromatographic column per
system, depending on the performance characteristics required for
analysis of the VOC mixture.
     Response:  The EPA agrees with these commenters that
temperature programmable GC's are not always necessary; that
requirement has been removed from PS 9.  The commenters should
note that temperature programmability will  decrease sample
elution time, which might be necessary to meet  the sampling
frequency requirement of the applicable  rule.
     The EPA agrees that calibration precision  is better  defined
as the error between  triplicate  injections  instead of  the
agreement between triplicate injections;  the definition has been
changed.
     The EPA considers  dual column/dual  detector systems  as  two .
separate  instruments,  and  thus  the source will  be required to
 conduct  performance  specification tests  for each sampling and
analytical  system.   This clarification has  been added to  PS  9.
      Comment:   A commenter  (IV-D-339)  recommended exempting from
 the stratification test method in Section 3.2  combustion stacks
 and 8-inch and smaller pipe, and making the sample point
 placement an item to be specified  by the source owner or
 operator in the enhanced monitoring protocol.   The commenter also
 stated that placing CEM's high on stacks adds unnecessary costs.
      Response:  The EPA has revised the instrument installation
 procedure to provide the source a great degree of discretion in
 locating a representative sampling site.
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      Comment:   One commenter (IV-D-260)  proposed language to
 amend Section 4.1 to require source owners or operators to
 identify a reasonable percentage,  instead of  98  percent,  of  the
 organic components by mass in the  effluent stream,  and proposed
 specifying that sources may use Method 18,  process  chemistry,  or
 previous studies  as a guide.   Another commenter  (IV-D-365)
 recommended use of 90 percent instead of 98 percent.   ;0ne
 commenter (IV-D-244)  requested clarification  of  whether
 Section 4.1 requires the analyst to determine which components
 constitute 98  percent of the mass  of the stream  or  98  percent  of
 the VOC components in the stream.                      •
      A commenter  (IV-D-258)  also recommended  amending  Section  4.1
 to allow more  than one chromatographic column, therefore  allowing
 more  than one  injector.   A commenter (IV-D-365)  also recommended
 modifying Section 4.1 to allow more flexibility  in  the required
 components of  a gas chromatographic system by adding "if
 necessary11  before the list of components.
      A commenter  (IV-D-258) proposed changing the term "injection
 loop"  and "loop"  in Sections  4.1 and 4.2  to the  more general and
 inclusive term "introduction  system."  Finally,  a commenter
 (IV-D-260)  proposed deleting  "temperature programmable" from
 Section 4.1.
      Response:  The language  in Section  4.1 has  been modified
 such  that  the  pollutants  to be  monitored will be determined by
 the applicable regulation or  permit.
      The  EPA considers dual column/dual detector systems as two
 separate  instruments,  and thus  the  source will be required to
 conduct performance  specification tests for each sampling and
 analytical  system.  This  clarification has been  added to PS 9.
 The injection  loop  system is widely used for the introduction  of
 gaseous samples to  the GC; however, the language has been
 expanded to allow alternative sampling systems, as long as the
performance requirements  of the  system are met.        |
     Comment:  A  commenter  (IV-D-258) recommended changing
 "chromatograph" in Section 4.2  to "chromatographic oven" because
the current language indicates  that the intent is to heat the
                              2-100

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entire chromatograph,  while the actual intent is to heat only the
injection system and the chromatographic oven.  A State agency
(IV-D-283)  also requested clarification of what constitutes a
sufficient showing of effectiveness for an unheated sampling
system, as discussed in Section 4.2.  A commenter (IV-D-365)
recommended amending Section 4.2 to require the sample loop and
chromatograph to be heated "if necessary."
     A few commenters  (IV-D-273; IV-D-339; IV-D-365) recommended
modifying the temperature requirement in Section 4.2.  One of
these commenters  (IV-D-339) recommended changing the minimum
temperature of 150 degrees Celsius to a requirement to maintain
the sample above its dew point.  Requiring a minimum temperature
of 150° is unnecessary to prevent condensation'and may cause
fouling and sampling problems.  This commenter also recommended
limiting the applicability of Section 4.2 to  samples that operate
above their dew point  or to combustion stacks.  The commenter
stated that heated sampling systems are appropriate only for hot
samples, such as  combustion stacks.  Another  of these commenters
 (IV-D-273) recommended modifying Section  4.2  to match the
requirements of Method 18, which specifies a  heated line,
temperature of 3  degrees above  stack  temperature or the
temperature necessary  to prevent condensation.  Finally, the
third  commenter  (IV-D-365) proposed a minimum temperature  of  110°
Celsius.
      One  commenter  (IV-D-349)  also  noted  that prescribing
specific performance  specifications inappropriately limits  a
source's  options  in  selecting an enhanced monitoring  instrument.
As  an example,  the commenter  discussed  in detail  the
 impracticability  of  requiring a sample  train to be maintained at
 150°  as  required  in  Section 4.2.
      Response;  The  wording in Section  4.2 has been clarified.
The EPA strongly  believes  that the heat-tracing of system
 components is  necessary in all cases, to insure no sample loss
 throughout the sampling system.  However, the EPA agrees with the
 commenter's concerns about the 150°C  temperature requirement.
 The EPA believes  120°C,  with  no cold  spots  in the system,  is
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 adequate to prevent  moisture condensation in the  sampling system.
 As discussed earlier,  this performance specification will be
 promulgated with this  action to 40  CFR Part  60, Appendix B, not
 the enhanced monitoring provisions  which the commenter is
 addressing.
      Comment:   A State agency (IV-D-283)  pointed  out that
 Section 4.3  refers to  a Section 4.3 of Appendix B,  Part 64, and
 stated  that  this section does not exist.   The commenter also
 recommended  specifying in Section 4.3  whether EPA protocol gases
 are required for calibration purposes.   Another commenter
 (IV-D-339)  recommended reducing the three-point calibration
 requirement  in  Section 4.3 to a one-point calibration,  because
 the three-point requirement reduces on-line  time  of  flame
 ionization detector  (FID)  gas chromatographic systems,  since the
 detector is  linear over six orders  of  magnitude.
      Response:   The  EPA has replaced referrals to other documents
 in PS 9  and  believes these changes  will  make the  document easier
 to use.   The calibration gas  requirements in PS 9 have  been
 clarified; cylinder  gases certified for  2 percent accuracy are
 required, a  gas dilution system allowance has  been added for
 added flexibility to the source.  The  EPA strongly believes in
 the use  of multipoint  calibrations,  particularly  for GC systems.
Although GC/FID systems  provide  good linearity over a wide range
 of  concentrations, multipoint  calibrations are needed to insure
 accurate  data and to correct  for detector noise and drift.
      Comment:   A State agency  (IV-D-283)  proposed amending
 Section  4.4  to  include as  audit  gases each organic anaiyte as
described in Section 4.3,  and  to determine calibration  error in
 Section  4.6 at  all three levels  for  each  organic anaiyte.
     Response:   The  EPA  has added the option of using a  Protocol
 1 gas mixture containing the compounds of  interest if EPA audit
materials are not available.
     Comment:   Certain commenters (IV-D-260;  IV-D-292;  IV-D-318)
recommended requiring sampling at two concentrations to determine
the 7-day calibration error, instead of requiring sampling at
three concentrations as  required in Section 4.6.   One commenter
                              2-102

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(IV-D-260)  proposed substituting the procedure discussed in
Section 4.1 of Appendix C,  and making conforming changes to
Section 6.1.1 of PS 102 as well as Section 4.6.  Another
commenter (IV-D-292) pointed out that two measurements are in
accord with accepted laboratory practices.  A commenter
(IV-D-318)  also requested that the EPA Technology Transfer and
Regulatory Support Group address the issue of the number of
samplings required.
     A commenter  (IV-D-260) also proposed amending Section 4.6 to
allow owners and operators to set calibration error by agreement
with permitting authorities, instead of setting the maximum
calibration error at 5 percent.  A local agency  (IV-D-524) noted
inconsistencies with 40 CFR Part 75.  The allowable calibration
error should be 2 percent instead of 5 percent, and the sample
reading time should be 15 minutes instead of 1 minute.
     Response:  The EPA believes that a three-point test of
instrument drift  is essential in order to document instrument
performance over  a  continuous period of time.  The calibration
error requirement has been expanded in PS 9 to 10 percent  instead
of the original 5 percent.  The EPA believes this expanded
requirement will  allow the source greater latitude in terms of
the number of  compounds which can be monitored with a GC system.
The differences in  requirements as to sampling frequency and
calibration error are dependant on the regulation and the  number
and types of pollutants required  for monitoring.
     Comment:  A  commenter  (IV-D-260) recommended amending
Section  4.7 to allow the possibility of using  calibration
techniques other  than  linear  regression analysis.  The  commenter
provided proposed language  that would require  the calibration
model  for each organic compound to have a goodness of fit  value
instead  of requiring a specific linear regression curve.   A
commenter  (IV-D-244) requested  clarification  of  the basis  for
selecting a  5  percent maximum deviation  in  Section 4.7.   The
commenter  asked whether a correlation r2  greater than or  equal  to
0.995  is necessary, noting that this  correlation would  be very
difficult  to meet.                                  •
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     Response:   The  linear regression analysis  is widely used and
 accepted  as a technique  to demonstrate linearity of  instrument
 response  over a  range  of concentrations.   The linearity of  the
 instrument is important  to insure  data accuracy.  The ;EPA
 believes  that the  5  percent deviation allowance per  triplicate
 injection and the  correlation  requirement  is reasonable and
 attainable; Test Method  18,  40 CFR Part 60, Appendix A, which is
 a GC procedure,  has  the  same 5 percent allowance for multiple
 calibration gas  injections.
     Comment;  A State agency  (IV-D-283) recommended changing the
 relative  error in  Section 4.8  from 10 percent to 5 percent,
 because the performance  audit  uses a  comparison to calibration
 gases, which are required to be very  accurate.  Another commenter
 (IV-D-332) recommended modifying the  relative error  specification
 in Section 4.8 to  cross  reference  the relative  accuracy
 specifications in  Appendices B and F  of 40 CFR  Part  60, while a
 local agency  (IV-D-402)  proposed relaxing  the relative | error
 specification from 10  percent  to 20 percent for emission
 standards with low concentrations  that  are lower than applicable
 federal standards.   The  local  agency  provided detailed examples
 of standards that  it imposed that  are far below federal
 requirements and for which 10  percent relative  error would be too
 stringent.
     Response;   The  EPA  believes the  10 percent performance audit
 deviation allowance  is reasonable,  considering  the wid^ range of
 pollutants potentially monitored with PS 9.  Performance audit
 samples are essential  to the verification of the" accuracy of the
 instrument.                                           :
     Comment;   A State agency  (IV-D-283) recommended delineating
 specific response  time criteria in Section 5.1.   An  industry
 commenter (IV-D-365)  provided proposed  text modifying Section 5.1
 to allow the use of  different  chromatographic columns run in
parallel to eliminate potential resolution interferences.
     Response:  An equation  and a requirement for the sampling
 system time constant has been added to Section 4.9.
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     Comment:   A State agency (IV-D-283)  recommended calling the
three-point calibration error test in Section 6.1.1 a linearity
test, similar to language in 40 CFR Part 75, to differentiate
between the three-point test and daily two-point calibration
error tests.  The agency also noted that the method of
calculation in Section 6.1.2 does not agree with the performance
specification criteria in Section 4.6.  Finally, the agency
recommended clarifying the testing strategy in Section 6.2 to
specify how many times audit gases are to be introduced into the
sampling system at the sampling probe, and to specify when audit
readings should be taken.
     Response:  The EPA believes there is some confusion on the
difference between the 7-day initial test and the daily
calibration criteria.  These sections have been rewritten in
order to clarify the requirements.  The requirements for carrying
out  the performance audit test have been clarified; the audit gas
shall be sampled three times and the average instrument response
shall be reported.
     Comment:  A State agency  (IV-D-283) noted  that Section 7
does not include all equations used for tests required by
Performance Specification 102.
     Response:  The EPA has added  equations  to  this section in
order to make  the procedure easier to use.
     Comment:  Two commenters  (IV-D-260, IV-D-365)  recommended
ways to reduce the reporting requirements  of Performance
Specification  102.  One  commenter  (IV-D-260) provided proposed
language to amend Section 8  that would  specify  ttiat data  sheets,
calculations,  CEM data records,  and  cylinder gas  or reference
material certifications  shall  be made available to the permitting
authority  upon request,  instead of requiring sources  to submit
these  records. Another commenter (IV-D-365) recommended
substituting  "applicable" for  "all"  in  Section 8,  to  acknowledge
that not all  of  the  requirements apply  to  each source.
     A State  agency  (IV-D-283)  recommended increasing the level
of detail  of  the  reporting  requirements.   The  agency stated that
Section 8  should provide for reporting  the results of calibration
                               2-105

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precision and performance audit tests.  The agency also
recommended requiring the submission of a signed document stating
that all testing procedures were completed according to the
requirements of Performance Specification 102.
     Response;  The EPA believes the reporting requirements for
this performance specification are reasonable.   The language in
this section has been altered for clarity.  The reporting
requirements will rely on the applicable regulation or permit.
                             2-106


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                                  TECHNICAL REPORT DATA
                             (Please read Instructions on reverse before completing)
1. REPORT NO.
  EPA-453/R-94-074b
IT
4. TITLE AND SUBTITLE
  Hazardous Air Pollutant Emissions from Magnetic Tape
Manufacturing Operations-Background Information for
Promulgated Standards                ^	
7. AUTHOR(S)
9. PERFORMING ORGANIZATION NAME AND ADDRESS

   Emission Standards Division (Mail Drop 13)
   Office of Air Quality Planning and Standards
   U.S. Environmental Protection Agency
   Research Triangle Park, NC  27711
 12. SPONSORING AGENCY NAME AND ADDRESS

   Director, Office of Air Quality Planning and Standards
   Office of Air and Radiation
   U. S. Environmental Protection Agency
   Research Triangle Park, NC 27711
                                                                 3. RECIPIENT'S ACCESSION NO.
                                          5. REPORT DATE
                                             November 1994
                                          6. PERFORMING ORGANIZATION CODE
                                                                 8. PERFORMING ORGANIZATION REPORT NO.
                                                                 10. PROGRAM ELEMENT NO.
                                           11. CONTRACT/GRANTNO.

                                            68-D1-0115
                                                                  13. TYPE OF REPORT AND PERIOD COVERED
                                           14. SPONSORING AGENCY CODE

                                             EPA/200/04
 15. SUPPLEMENTARY NOTES
 16. ABSTRACT
     A final rule for the regulation of hazardous air pollutant emissions from magnetic tape manufacturing
            Tbeingpromufgated under the authority of Sections 112,  114, 116, and 301 of the Clean A!T
            nded I 1990.  This document presents the response to public comments received on the
 proposed rule and changes made to the rule between proposal and promulgation.	_	
                                      KEY WORDS AND DOCUMENT ANALYSIS 	
  17.
                    DESCRIPTORS
    Air Pollution
    Hazardous Air Pollutants
    Magnetic Tape Manufacturing
    National Emission Standards
  18. DISTRIBUTION STATEMENT
                                                 b. IDENTIFIERS/OPEN ENDED TERMS
                                                   Air Pollution Control
                           19. SECURITY CLASS (Report)
                              Unclassified
                                                  20. SECURITY CLASS (Page)
                                                     Unclassified
                                                                                     c. COSATI Field/Group
21. NO. OF PAGES
  115
                                                                                     22. PRICE
 EPA Form 2220-1 (Rev. 4-77)PREVIOUS EDITION IS OBSOLETE

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