United States      Office of Air Quality       EPA-450/3-81 -008b
           Environmental Protection  Planning and Standards     September 1987
           Agency         Research Triangle Park NC 27711

           Air
&ERA     Rubber Tire           Final
           Manufacturing        EIS
           Industry —
           Background
           Information for
           Promulgated
           Standards

-------

-------
                          EPA-450/3-81-008b
          Rubber Tire
 Manufacturing Industry —
  Background Information
for Promulgated  Standards
      Emission Standards and Engineering Division
      u S Environmental Proiedion

            aS Bo« 12th Floor
           . IL . 60604-3590
      U.S. ENVIRONMENTAL PROTECTION AGENCY
           Office of Air and Radiation
      Office of Air Quality Planning and Standards
      Research Triangle Park, North Carolina 2771 1

              September 1987

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

-------
                     ENVIRONMENTAL PROTECTION AGENCY

                          Background Information
                                and Final
                      Environmental Impact Statement
                  for/rubber Tire Manufacturing Industry

                               Prepared by:
 /
 Jack R. Farmer                                         (Date)
 Director, Emission Standards and Engineering
   Division
 U.S. Environmental Protection Agency
 Research Triangle Park, North Carolina  27711

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

• 2.   Copies of this document have been sent to the following Federal
      Departments: Labor, Defense, Transportation, Commerce, Interior,
      and Energy; the Council on Environmental Quality; members of the
      State and Territorial Air Pollution Program Administrators; the
      Association of Local  Air Pollution Control Officials;  EPA Regional
      Administrators; and other interested parties.

 3. •  For additional information contact:

      Ms. Dianne Byrne or Mr. Gilbert Wood
      Standards Development Branch (MD-13)
      U.S. Environmental Protection Agency
      Research Triangle Park, NC  27711

 4.   Copies of this document may be obtained from:

      U.S. EPA Library (MD-35)
      Research Triangle Park, NC 27711
      Telephone:  (919) 541-2777
      National Technical Information Service
      5285 Port Royal  Road
      Springfield, VA 22161
                                   n

-------

-------
                           TABLE OF CONTENTS

Chapter                                                       Page

1.0  SUMMARY	     1-1
     1.1  Summary of Changes Since Proposal  	     1-1
     1.2  Summary of Impacts of Promulgated  Action. . . .     1-3
2.0  SUMMARY OF PUBLIC COMMENTS 	     2-1
     2.1  Selection of Affected Facilities	     2-4
     2.2  Modification and Reconstruction 	     2-7
     2.3  Emission Control Technology 	 .....     2-10
     2.4  Selection of Emission Limits and VOC Use
          Cutoffs	     2-11
     2.5  Compliance Bubble 	     2-26
     2.6  Performance Test Methods and Monitoring ....     2-29
     2.7  Alternative Compliance Methods	     2-32
     2.8  Recordkeeping and Reporting 	     2-37
    . 2.9  Miscellaneous	     2-38
                             LIST OF TABLES

2-1. List of Comments on Proposed Standards of
     Performance for Rubber Tire Manufacturing  	     2-2
                                   iv

-------

-------
                              1.0  SUMMARY

     On January 20, 1983, the Environmental  Protection Agency (EPA)
proposed standards of performance for the rubber tire manufacturing
industry (48 FR 2676) under authority of Section 111 of the Clean Air
Act.  Public comments were requested on the proposed standards in the
Federal Register.  There were nine commenters, mainly composed of tire
manufacturers.  Also commenting were the Rubber Manufacturers Association
and the Alabama Department of Environmental  Management.  The comments
that were submitted, along with responses to these comments, are
summarized in this document.  The summary of comments and responses  serves
as the basis for the revisions made to the standard between proposal
and promulgation.
1.1  SUMMARY OF CHANGES SINCE PROPOSAL
     The proposed standards have been revised as a result of reviewing
public comments.  The format of the volatile, organic compounds (VOC)  use
cutoffs for undertread cementing and sidewall cementing facilities has
been changed from a grams of VOC per tire basis to an equivalent total
(uncontrolled) VOC use basis.  A VOC use cutoff, an emission limit,  and
an alternative compliance method have been added for green tire spraying
facilities that use organic solvent-based sprays.  A VOC use cutoff  has
also been added for Michel in-A, -B, -C-automatic facilities.  The
format for the proposed bead cementing emission limit has been changed
from a yrams per tire basis to an equivalent grams per bead basis.  The
proposed definition of "month" also has been changed.  These changes
are explained in the responses to the comments that are provided in
Chapter 2 of this document.
     In addition to changes made to the proposed standards based on  public
comments received, inside and outside green tire spraying operations
that are performed in the same spray booth have been designated one
affected facility.  Under the proposed standards, the limits for each
inside and outside green tire spraying operation would have been met by
using water-based sprays.  Since there are different spray formulations
for inside and outside water-based sprays, it was appropriate to have

                                  1-1

-------
separate limits for the two types  of sprays,  and it was  simpler to
treat each inside water-based spraying and each outside  water-based
spraying operation as separate affected facilities.  With the addition of
emission limits for organic solvent-based green tire spraying operations,
which would be met using capture and control  technology, it is appropriate
to designate the spray booth as the affected  facility.  This would be
the narrowest definition of a green tire spraying facility to which a
capture and control system could be applied.   It would not be feasible
to construct an emission reduction system to  control emissions from
separate inside and outside green tire spray  applicators (nozzles)
within one spray booth.  Consequently, a green tire spraying facility
now is defined as the spray booth, spray application equipment, and
related equipment used to apply inside and/or outside sprays to a green
tire.  However, because no emission reduction systems are anticipated for
control of water-based sprays, separate emission limits for these
sprays have been retained.
     The monitoring requirements have changed for owners and operators
who use a  carbon adsorber to achieve compliance with a percent reduction
requirement by meeting equipment specifications.  At proposal, such
owners and operators would have been required, upon EPA promulgation of
the  necessary  continuous monitor performance specifications, to install
an emissions monitor to measure the VUC concentration of the exhaust
gases.  The Agency has  not developed such continuous monitor performance
specifications for VUC.  However,  organics monitoring devices are
available  that can serve as  concentration level  indicators  for determining
proper  operation  and maintenance without the necessity  for  performance
specifications.   The  final  standards  have been  revised to  require  the
installation  of  organics concentration  monitoring  devices  (where  carbon
adsorbers  are used to  achieve  compliance with  a  percent  reduction  require-
ment by meeting  equipment  specifications) for  the  purpose  of  determining
proper operation and maintenance  of the carbon  adsorbers.
      Reporting requirements  have  been  changed  to reflect  the  EPA's
efforts to increase  the efficiency of  enforcement  activities.   Once
 every 6 months,  facilities are being  required  to report periods  when
 the applicable emission limit is  exceeded  and  when the  operating
 parameters being monitored are not within acceptable limits.

                                   1-2

-------
     Language has been added to the preamble and regulation to clarify
that the percent emission reduction requirement and monthly VUC use cut-
offs for undertread cementing, sidewall  cementing, green tire spraying,
Michelin-A, Michelin-B, and Michelin-C -automatic operations apply
to all VOC used in cements and organic solvent-based green tire sprays^,
including that VOC used for tire types other than those defined in the
regulation [§6U.541(a)].
1.2  SUMMARY OF IMPACTS OF PROMULGATED-ACTION
1.2.1  Alternatives to Promulgated Action
     The regulatory alternatives are discussed in Chapter 6 of the
background information document for the proposed standards (BIO) (EPA-45U/
3-81-UU8a).  These regulatory alternatives reflect the different levels
of emission reduction from which one is selected that represents best
demonstrated technology  (BDT), considering costs, nonair quality health,
and environmental and economic impacts for rubber tire manufacturing.
These alternatives remain the same.
1.2.2  Environmental Impacts .of Promulgated Action
     The environmental impacts are discussed in Chapter 7 of the BID.
These impacts are based  on the different levels of emission reduction
as reflected by the regulatory alternatives.  The environmental impacts
were  one factor used in  selecting the proposed standards.
     The environmental impact figures have been revised to reflect
changes in the  estimates of the emission level under baseline control,
and changes that were made to the standards after proposal.  Detailed
calculations are provided in docket entry IV-B-12.
     At proposal, the  baseline level of emission control was assumed to
be 70 percent overall emission reduction, using capture and control
equipment, at each undertread cementing operation, each tread end
cementing  operation, each 'bead cementing operation, and each green tire
spraying operation where organic solvent-based sprays are used.  In
addition,  some  green tire spraying operations were assumed to use water-
based sprays, and VOC emissions from sidewall  cementing operations were
assumed to be uncontrolled.   This baseline  reflects the level of emission
reduction  recommended  in the  control technique guideline  (CTG)  document,
"Control of Volatile Organic Compound Emissions from Manufacture of
Pneumatic  Rubber Tires"  (EPA-450/2-78-U30).
                                    1-3

-------
     Since publication of the CTG,  many  States  where rubber  tire
manufacturing plants are located have adopted regulations  in their State
implementation plans (SIP's) that can be met  without installing capture
and control equipment at tread end cementing  and bead cementing operations.
The EPA believes that this emission control scenario is a  more representative
emissions baseline and, therefore, has revised the baseline  level  of emission
control accordingly.  Capture and control equipment is no  longer assumed
to be used at these two types of operations  under the emissions baseline.
     The addition of percent emission reduction requirements for green
tire spraying operations where organic solvent-based sprays  are used
also has changed the environmental impact of  the standards.   These impacts
were previously based on the use of water-based sprays at  all affected
green tire spraying operations.  The environmental impact  of the promul-
gated standards are based on the use of  some  organic solvent-based
sprays  at  46 percent of  the  affected green tire spraying operations.  A
75 percent efficient emission reduction  system was  assumed to be used
whenever  organic solvent-based sprays were used.
1.2.3   Energy,  Control Costs, and  Economic Impacts  of  Promulgated Action
     The  energy impacts  are discussed in Section 7.4 of the BIO.  VOC
control cost impacts  for the regulatory  alternatives,  costs to  comply
with Occupational Safety  and Health  Administration  regulations, and
compliance costs  of other environmental  regulations  are discussed in
Chapter 8 of  the  BID.   Chapter  9 of  the  BID  describes  the economic
 impacts of the  proposed standards.  The  changes made  in the  standards
 have  no effect  on these impacts  for  the  regulatory  alternatives.
      The  control  costs calculated  for the promulgated  standards have
 been  revised to reflect changes  in assumptions  used to estimate baseline
 control costs  and changes in the standards since  proposal.   Detailed
 calculations are provided in docket  entry IV-B-12.
      At proposal, the assumptions used  to calcualte the baseline  control
 costs were:   (1)  a separate capture and control  system would be used  at
 each undertread cementing operation, each tread end cementing operation,
 and each  bead  cementing operation; and   (2) no capture and control
 systems would  be used at green tire spraying operations and sidewall
 cementing operations.  The  assumptions  used  to calculate  the baseline
 control costs  for the promulgated standards  were:  (1) a  separate
                                   1-4

-------
capture and control  system would be used at each  undertread cementing
operation; (2)  54 percent of the green tire spraying operations would
use only water-based sprays and, therefore, incur no control  system
costs; (3) 46 percent of the green tire spraying operations would use
some organic solvent-based sprays and would use capture and control
systems to reduce emissions; (4) no capture and control systems would
be used at sidewall  cementing operations, tread end cementing operations,
and bead cementing operations.
     The addition of percent emission reduction requirements for green
tire spraying operations where organic solvent-based sprays are used
also has changed the cost impact of the standards.  These impacts were
previously based on the use of water-based sprays at all affected
green tire spraying operations.  The cost impact of the promulgated
standards is based on the use of some organic solvent-based sprays at
46 percent of the affected  green tire spraying operations.  A 75 percent
efficient emission reduction system was assumed to be used whenever
organic solvent-based sprays were used; and a particulate removal
device was assumed to be used upstream of the VOC control device.
Consequently, the energy and control cost  impacts of the promulgated
standards increased slightly.  However, the economic impacts of the
promulgated standards remain essentially the same.
1.2.4  Other Considerations
     Section 7.5.3 of the BID concludes that the  regulatory alternatives
allow each company to develop the  optimal  strategy of emission reduction
for each  facility, and that future  control options, therefore, are not
expected  to  be  affected  adversely.   The  changes to the  proposed standards
have  no effect  on this conclusion.
      1.2.4.1  Environmental  and  Energy  Impacts of Delayed Standards.
Section 7.5.4 of the BID  concludes  that  if standards implementation
is delayed,  new plants  in National  Ambient Air Quality  Standard  (NAAQS)
nonattainment areas  for  ozone would be  subject to SIP  requirements.
Delay  in  implementation  of  the  standards of performance, therefore,
would  result in about a  5  percent  increase in  annual nationwide VOC
emissions  from  tire  manufacturing  plants.  This projected impact  has
not changed  since proposal  of the  standards.
                                   1-5

-------
     1.2.4.2  Urban, Community.  Socioecononvic.  and Inflationary  Impacts.
Section 7.5.2.1 of the BID concludes  that the regulatory alternatives
are not expected to have an adverse impact on urban areas or communities,
Section 9.3 of the BID concludes that the socioeconomic and inflationary
impacts of the regulatory alternatives are minimal.  Changes to  the
proposed standards have not affected these conclusions.
                                   1-6

-------
                    2.0  SUMMARY OF PUBLIC COMMENTS
                                                                •.ts

     A total  of nine letters commenting on the proposed standards and
on the BID (EPA-450/3-81-008a)  were received.   Two speakers  made presen-
tations at the public hearing on the proposed  standards.  Presentations
and comments  made at the public hearing were recorded,  and  a transcript
of the hearing was placed in the project docket (docket A-80-9,  entry
number IV-F-1).  A list of commenters,  their affiliations,  and  the EPA
docket entry  number assigned to their correspondence or presentations
is presented  in Table 2-1.
     For the  purpose of orderly presentation,  the comments  have  been
organized under the following topics:
     2.1   Selection of Affected Facilities
     2.2   Modification and Reconstruction
     2.3   Emission Control Technology
     2.4   Selection of Emission Limits and VOC Use Cutoffs
     2.5   Compliance Bubble
     2.6   Performance Test Methods and Monitoring
     2.7   Alternative Compliance Methods
     2.8   Recordkeeping and Reporting
     2.9   Miscellaneous
                                2-1

-------
      Table 2-1.  LIST OF COMMENTERS ON PROPOSED  STANDARDS
          OF PERFORMANCE FOR RUBBER  TIRE MANUFACTURING
Docket Entry Number3             Commenter and  Affiliation

     IV-D-1                      Mr.  Frank T. Ryan
                                 Rubber Manufacturers,.,Association
                                 1901 Pennsylvania  Avenue,  N.  W.
                                 Washington, DC 2U006

     IV-D-2                      Mr.  Bill  Wood
                                 Engineering Services  Section/Air
                                   Program
                                 Alabama Department of Environmental
                                   Protection
                                 State Capitol
                                 Montgomery, AL 36130

     IV-D-3    .                  Mr.  Robert M.  Walter
                                 The  Firestone  Tire and  Rubber Company
                                 1200 Firestone Parkway
                                 Akron, OH 44317

     IV-D-4                      Mr.  E.J.  Burkett
                                 The  Goodyear Tire  and Rubber  Company
                                 Akron, OH 44316

     IV-D-5                      Mr.  Lynn  B. Cooper
                                 Michel in  Tire  Corporation
                                 P.O. Box  2846
                                 Greenville, SC 29602

     IV-D-6                      Mr.  Daniel J.  Pyanowski
                                 Uunlop Tire and Rubber Corporation
                                 Box  1109
                                 Buffalo,  NY 1424U

     IV-D-7                      Mr.  Geoffrey K. Barnes
                                 Squire, Sanders, and  Dempsey
                                 [for Bridgestone Tire Manufacturing
                                    (U.S.A.),  Inc.]
                                 1800 Union Commerce Building
                                 Cleveland, OH  44115

     IV-D-8                      Mr.  Robert C.  Miles
                                 Uniroyal, Incorporated
                                 World Headquarters
                                 Middlebury, CT 06749
                                2-2

-------
               Table 2-1.  LIST OF COMMENTERS ON PROPOSED  STANDARDS
                 OF PERFORMANCE FOR RUBBER TIRE MANUFACTURING
                                 (Concluded)
Docket Entry Number3             Commenter and Affiliation

     IV-D-9                      Mr. W.C.  Lang
                                 The General  Tire and Rubber Company
                                 One General  Street
                                 Akron,  OH 44329

     IV-F-2                      Mr. Ron Clark
                                 The B.F.  Goodrich Company
                                 500 South Main Street
                                 Akron,  OH 44318

     IV-F-3                      Mr. Frank T. Ryan
                                 Rubber  Manufacturers Association
                                 1901 Pennsylvania Avenue,  North West
                                 Washington,  D.C. 20006
aThe docket number for this project is A-80-09.   Dockets are on file
 at the EPA Headquarters in Washington, D.C., and at the Office of Air
 Quality Planning and Standards in Durham, N.C.
                                  2-3

-------
2.1  SELECTION OF AFFECTED FACILITIES
2.1.1  Bead Cementing
Comment:
     Two commenters (IV-D-2, IV-D-4) requested that bead cementing not
be included as an affected facility because:  (1)  this  type of cementing
uses only a small quantity of VOC and it is not feasible to recover a
high percentage of emissions; and (2) the proposed standard would not
appreciably reduce VOC emissions, but would add significantly to the
economic burden of each company and control agency.
Response:
     As required by the Clean Air Act, the Administrator has published
in 40 CFR Part 60, Subpart A, a list (called the "priority list") of
stationary sources, each included ". . . if in his judgement it causes,
or contributes significantly to, air pollution which may reasonably be
anticipated to endanger public health or welfare."  The priority list
includes synthetic rubber, of which rubber tire manufacturing is a
part, as a-source category ranked twentieth of 59 source categories.
     The development of a standard for bead cementing, as well  as other
sources in a rubber tire manufacturing plant, is consistent "with the
requirements of the Clean Air Act, that is, to set standards that
reflect the degree of emission reduction achievable through the appli-
cation of BDT at each new source for which BDT can be identified.  In
determining BDT, the Agency takes into consideration the cost associated
with the emission reduction requirements.
     The EPA has identified BDT for bead cementing facilities.   Low VOC
use has been demonstrated at bead cementing facilities at the majority
of existing plants.  For each company that supplied data, at least one
plant emits 10 grams per tire (5 grams per bead) or less VOC from bead
cementing operations without using emission reduction systems.   In the
EPA's judgement, this has resulted from the employment of low VOC use
technology and good work practices at bead cementing facilities.  The
standard for bead cementing [proposed at 10 grams of VOC per tire (10
g/tire), revised to 5 grams of VOC per bead (b g/bead) (see Section 2.4.2
of this document regarding bead cementing emission limit)] consequently
represents an emission level which has been demonstrated to be achiev-
able without the use of VOC emission controls.  Therefore, the standard

-------
can be met without incurring the costs associated with an emission
reduction system.
     The EPA disagrees that no significant emission reductions would
be achieved with the bead cementing standard.  For example, the average
uncontrolled VOC emission rate for the few existing plants exceeding
the 5 g/bead limit is about 9.3 g/bead.  If the grams per bead emission
rate at one medium-sized passenger tire plant (30,OUO tires per day)
were reduced from 9.3 g/bead to 5 g/bead, the overall VOC emission
reduction would be about 70 megagrams (Mg) per year.  The EPA considers
this amount of emission reduction to be significant.
     The EPA also disagrees that the standards for bead cementing would
add significantly to the economic burden of each company and control
agency.  An analysis of the recordkeeping and reporting costs for the
manufacturers and for control agencies to assure compliance with the
standard shows that the costs would be reasonable (see docket entry number
IV-B-6).  No information was provided by the commenters to support their
claim regarding an economic burden.  For the above reasons, the EPA is
not changing its decision to select bead cementing as an affected facility.
2.1.2  Tread End Cementing
Comment:
     One commenter (IV-D-4) requested that manual tread end cementing
be exempted from the proposed standard for tread end cementing or that
manual tread end cementing be designated as new source performance
standard (NSPS) equivalent technology.  The commenter wrote that because
of very low solvent usage, it is technically unreasonable to further
reduce emissions from manual tread end cementing.  The commenter further
noted that attempts to recover emissions from manual tread end cementing
have been unsuccessful.
Response:
     The standard for both automatic and manual  tread end cementing is
10 g/tire.  The 10 g/tire limit is based on emission rates which have
been demonstrated to be achievable throughout the industry without the
use of capture and control technology.  Therefore, any difficulty
associated with recovering VOC from tread end cementing facilities will
not affect the ability of those facilities to comply with the standards.
Also, the commenter1s company would not need to reduce emissions

                                  2-5

-------
further at manual  tread end cementing,  as  available data indicate that
VOC use at all existing tread end cementing operations  at that company's
plants is less than 1U g/tire.
     Although emissions from manual  tread  end cementing may  be as
low as 2 g/tire (see BIO, Section 4.3.3),  use of manual  tread end
cementing is not conclusive evidence that  a facility is in compliance
with the tread end cementing standard that the EPA has  selected as
reflecting 8DT, since some plants that currently employ manual tread
end cementing exceed the 10 g/tire limit.   The average  emission factor
for existing manual tread end cementing facilities that exceed the
limit is about 22.5 g/tire.  By exempting  manual tread  end and cementing
operations from the standards or by treating them as NSPS equivalent
technology, an additional 100 Mg of VOC per year could  be emitted from
a medium-sized plant  (30,000 tires per day).  Designating manual tread
end cementing as NSPS equivalent technology or exempting it from the
standards, therefore, would not be appropriate.
2.1.3  Combined Affected Facilities
Comment:
     One commenter  (IV-D-3) requested that the standards be revised to
provide for a combination of emission limits in those cases where
affected facilities are combined.  The commenter wrote  that an example
of this situation would be one separate undertread cementing facility
combined with a separate sidewall cementing facility so that both
operations would be performed in one operation.  The commenter stated
that  in the future  some tire plants may adopt operations which would
combine affected facilities into a single operation.
Response:
      The  commenter  referred specifically to the situation where
undertread  cementing  and sidewall cementing are performed simultaneously.
The  standards  provide  for  combined undertread and  sidewall cementing
operations  through  §60.541(a), which defines an undertread cementing
operation  as  "....  a  system used to  apply cement to a  continuous  strip
of  tread  or combined  tread/sidewall  component."   (emphasis added).   The
decision  to apply the standard  for undertread  cementing  to operations
where undertread and  sidewall  cementing are  combined is  based  on  cost
analyses  and  information  from tire manufacturers that  employ  combined

                                   2-6

-------
cementing operations.  The cost to control  VOC emissions from combined
facilities is essentially the same as the cost to control VOC emissions
from a single undertread cementing facility because cement application
equipment and emission reduction systems that would be used for a
combined undertread and sidewall cementing operation are similar in
size and cost to equipment and control systems used for a separate
undertread cementing operation.  Thus, there is no reason to allow
addition of the cost-based solvent use cutoffs for undertread cementing
and sidewall cementing.
     At this time, the EPA knows of no other operations that could be
combined and for which combined limits might be appropriate.  If opera-
tions are-combined in the future, the EPA will set standards appropriate
to the combined operations.
2.2  MODIFICATION AND RECONSTRUCTION
2.2.1  General Provisions for Modifications
Comment:
     Two  commenters  (IV-D-1, IV-D-4) asked that the general regulatory
language  of 40 CFR 60.14 be reaffirmed in the rubber tire NSPS to ensure
that normal changes or variations in the operation of tire plants would
not be considered modifications.  The commenters wrote that most changes
that occur at an affected facility are in the tire type produced.  As a
facility  is designed initially  to produce a large variety of tire types,
such changes would not constitute a modification.  The commenters further
asked that rubber compounds, tread stock, tire components, sprays, and
unfinished tires be  considered  "raw materials" for the purposes of
§60.14, thereby excluding them  from the modification provisions.  The
commenters also noted that Section 5.3.1.1.2  (p. 5-4) of the BID is
inconsistent with the modification provisions and should be clarified.
Response:
     The  EPA agrees with the commenters that  routine changes of the type
described in the comments would not be considered modifications.  The EPA
also agrees that under §60.14(e), rubber compounds, tread stock, tire
components, sprays,  and unfinished tires are  "raw materials" which, if
routinely changed, and provided the raw material change  is within the
facility's original  or amended  design specifications, would not bring
an  existing facility within the scope of the modification provisions.

                                  2-7

-------
However, changes that are not within the facility's design specifications
and that would increase the emission rate could be considered modifications,
     The EPA agrees that Section 5.3.1.1.2 of the BID is inconsistent
with the modification provisions.  Line 7 on page 5-5 should read "Either
change, if within the design specifications of the affected facility,
would not be considered a modification."  An errata sheet is being
added to the BID to correct this error.
2.2.2  Retrofit Situations
Comment:
     One commenter (IV-D-2) stated that the proposed rules should
include more provisions for retrofit situations since most changes in
the industry are expected to be modifications and reconstructions.
Another commenter  (IV-D-6) felt that existing plants will be subject to
the modification'and reconstruction provisions since existing plants
are in  a constant  state of improving the manufacturing method of tires
in  order to  remain competitive.  This commenter (IV-D-6) also wrote
that modifications will arise as market demands change  for different
tires,  since the changes will affect existing facilities rather than
cause  construction of  new  facilities.
Response:
     The commenters  indicated that most of  the facilities that will  be
subject to  the  standards will be modified  and reconstructed  facilities
in  existing plants,  rather than  new facilities in  new plants.  Although
the EPA expects  that most  facilities that  will be  subject to the  standards
will  be new facilities  in  existing  plants,  the EPA  recognizes that  in  some
cases  existing  facilities  could  become  subject to  the standards through
modification and reconstruction.  Consequently, the  installation  and
operating  costs of emission  reduction  systems retrofitted on single
existing facilities  were  used  in  selecting BDT for each affected  facility.
The costs  and  emission reductions for  the  retrofitted control systems
were developed  for a range of  uncontrolled VOC emission rates and used
 as a  factor in  developing VOC  use cutoffs  for undertread cementing,
 sidewall cementing,  and green  tire  spraying facilities  where organic
 solvent-based sprays are  used.   Neither commenter suggested any  specific
 reason that the resulting standards do not adequately  reflect  retrofit
 situations, and the  EPA is aware of none.   The  EPA therefore believes

                                   2-8

-------
that the standards of performance give sufficient consideration to
retrofit situations.
2.2.3  Determination of Modifications and Reconstructions on a Case-by-Case
       Basis
Comment:
     One commenter (IV-D-9) believes that the Administrator should be
authorized to review the conditions which may trigger modification and
reconstruction and make certain exceptions on a case-by-case basis.  In
particular, the commenter felt that those operations which would require
an expenditure of over $2,QUO per megagram of solvent removed should be
given special consideration.
Response:
     The installation and operating costs of emission reduction systems
retrofitted on single existing facilities were used in selecting BUT
for each affected facility.  These same retrofit cost analyses served
as the basis for selecting the VOC use cutoffs for undertread cementing,
sidewall cementing, and organic green tire spraying facilities that use
VOC-based sprays (see Sections 2.4.1 and 2.4.8 of this document).
Single-line retrofit controls were selected because some industry
representatives claim that most facilities to be affected by the standards
will be located at existing plants.  The emission limits for bead
cementing and tread end cementing facilities are based on VOC emission
rates currently achievable by existing facilities (see Sections 2.4.2
and 2.1.2 of this document).  Modifications to existing bead cementing
and tread end cementing facilities are not expected to affect adversely
the ability of these facilities to meet their respective emission
limits.  Since the effect of the standards on existing facilities  is
reflected in the VOC use cutoffs and emission limits, providing modified
affected facilities with exemptions to the standards on a case-by-case
basis is not considered necessary.
     However, 40 CFR 60.15 provides for the Administrator's case-by-case
review of whether a facility is considered reconstructed and therefore
subject to the standards.  Criteria used by the Administrator to determine
whether a facility is considered reconstructed and exempt from the

                                  2-9

-------
standards are:  (1) whether the caiaital  costs exceed 50 percent of the
cost to build a new facility, and (2) whether it is technologically and
economically feasible to meet the standards.
2.3  EMISSION CONTROL TECHNOLOGY
2.3.1  Michelin Tire Corporation Affected Facilities
Comment:
     One commenter (IV-D-5) stated that emission reduction technology
that is adequately demonstrated to be technically and economically
feasible does not exist for Michelin-C-automatic operations.  The
commenter stated that the operation is relatively new, and equipment
configurations make enclosure and capture of VUG very difficult.
Capture efficiencies below 50 percent have been obtained.  The commenter
wrote that  efforts to improve capture efficiency have produced several
productivity and mechanical problems.  An attachment, placed in confi-
dential files at the EPA, was included by the commenter to outline some
of  the  technical problems involving VOC capture at this facility.
Response;.
     The proposed standard for Mic'helin-C-automatic operations [§6U.542(a) (9)]
is  based on the  EPA's determination that 65 percent emission reduction
represents  application  of BOT.   The EPA based that determination on  its
knowledge of the process and  its  judgment on the potential  for emissions
capture.   (See  response to comment 2.7.3.1.)  The  information submitted
by  the  commenter after  proposal  did not demonstrate that 65 percent
emission  reduction  does not  represent BOT at Michelin-C-automatic
operations. Rather, the information confirmed  that the  operations  can
achieve a  capture efficiency  well  beyond the level the commenter  now claims
 is  achievable.   The  EPA believes that improvements could  be made  to  the
 existing  design  of  the  capture  system that  would  result  in  at least
 70 percent  efficient capture.  These  improvements  include installing
 floor sweeps in the  cement  application  area and keeping  all exhaust
 hoods close to the tire during  cement  application.  Increased efficiency
 of the capture/control  system could  be  achieved by venting  all  hood
 exhaust, including floor sweeps, to  the  control device.   Therefore,  the
 proposed 65 percent reduction requirement  for  Michelin-C-automatic
 operations has not been changed.
                                   2-1U

-------
2.3.2  Carbon Adsorber Performance
Comment:
     One commenter (IV-D-8) felt the assumption that a carbon adsorption
system will  operate at a 95 percent rate of efficiency cannot be supported.
The commenter stated that since a carbon adsorber has not been demonstrated
to attain a 95 percent efficiency for tire manufacturing applications,
it does not make sense to write a regulation that is not attainable.
Response:
     The standards are based on a 95 percent efficient carbon adsorber
unit, because this level of control has been demonstrated to be reasonable
for other applications which have uncontrolled exhaust streams with
similar VOC compositions and concentrations.  The selection of a
95 percent efficient carbon adsorber also is based in part on the
performance of an adsorber used to control undertread cementing emissions.
     VOC removal  efficiencies exceeding 95 percent have been achieved
where carbon adsorbers have been employed in rubber hose, fan belt,
rubber glove, roof coating,, and pressure sensitive tapes and labels
manufacturing operations.  Exhaust .gases from these operations are similar
in VOC concentration and composition to exhaust gases from tire manufacturing
operations (see BID, Section 4.2.2).
     Removal  efficiencies of 90 percent have been observed for a carbon
adsorber used to control emissions from undertread cementing (see BID,
Section 4.3.1).  However, discussion with the owners of the undertread
cementing control unit indicated that removal efficiency of the device was
impaired because of design problems which did not permit full desorption
of the carbon beds prior to their being placed back on line.  Based on
the level of control demonstrated by carbon adsorbers in other applications,
results of tests performed on the adsorber servicing undertread cementing,
and improvements that could be made to this control device, the EPA has
determined a 95 percent removal efficiency to be achievable.
2.4  SELECTION OF EMISSION LIMITS AND VOC USE CUTOFFS
2.4.1  VOC Use Cutoffs and Definition of the Total Number of Tires
       Processed (Tn)
Comment:
     Several  commenters (IV-D-1, IV-D-3, IV-D-4, IV-D-b) contended that the
proposed method of counting tires at an affected facility to determine the

                                  2-11

-------
gram per tire VOC usage rate [T0 in §60.542(c)(2)] would penalize tire
manufacturers who eliminate organic solvent application for part of
their production at a particular affected facility.  Several  commenters
(IV-D-1, IV-D-3, IV-Q-4, IV-D-5, IV-U-6, IV-F-2) subsequently requested
that the EPA delete the phrase "... which receive an application of cement
(green tire spray)" from the proposed definition of T0.  These commenters
suggested that, for the purpose of performance test calculations in
§60.543(c)(2), T0 should equal the total number of tires or tire components
processed at an affected facility.  One commenter (IV-D-5) contended
that under the proposed definition of T0, an affected facility theoreti-
cally could be required to install VOC control  technology when less
than 10 percent of the tires or tire components passing through the
affected facility actually are cemented.  Another commenter (IV-F-2,
p. 25) showed that under the proposed definition of T0, add-on emission
controls would be required for one of his plants' undertread cementing
operations even though 60 percent of the production is not cemented.
This commenter explained that if 0.1 yram of VOC were applied to each
tire presently not cemented, at the facility, no add-on controls would
be required  because the proposed definition of T0 would count all
tires cemented.  The commenter  (IV-F-2) remarked that, based on the
example presented above, the  proposed definition of T0 would have  a
result which  is contrary to the EPA's intent to have tire manufacturers
reduce  or eliminate  organic solvent  use.  This commenter  stated that  if
the  definition of T0 were  revised  as requested, credit would be given
to  his company  for eliminating the application of  undertread cement to
a  portion of  its production and, consequently, no  VOC  controls would  be
requi red.
Response:
      A.   VOC Use Cutoffs and  Method  of  Counting Tires  —  Undertread
      Cementing  and Sidewall Cementing
      The  proposed  standards would  require  that  VOC emissions  be  reduced
by 75 percent at affected  undertread cementing  and sidewall  cementing
 facilities  where in  each  calendar month VOC use  exceeds  an  average of
25 g/tire [§60.542(a)(1)  and  (2)].  The percent  emission  reduction
 requirement reflects the  application of BDT as  required  by  the  Clean
 Air Act.

                                   2-12

-------
     The gram per tire VOC use cutoffs were provided to exempt from the
emission reduction requirements facilities that would incur control
costs which the Administrator judged to be too high for the emission
reduction achieved.  In selecting the 25 g/tire number, the EPA recognized
that some tires receiving undertread or sidewall cement would receive less
than 25 grams of VOC and others would receive greater than 25 grams of VOC,
but, on the average, VOC use at each the facility would be 25 g/tire,
assuming that all tires received an application of cement.
     The commenter (IV-F-2) presented a situation where a large portion
of the tire production does not receive undertread cement.  However, VOC
use is greater than 25 g/tire for the portion of production receiving
cement, the only tires that would be counted under the proposed definition
of T0.  In this situation, the EPA agrees that the proposed definition
of T0 could result in requiring a manufacturer to reduce VUC emissions
where the control costs were judged unreasonable for the emission
reduction achieved.
     With this concern in mind, the EPA has revised the cutoffs.  The
revised cutoffs are based on total (uncontrolled) monthly VOC usage at
the facility.  The  total (uncontrolled) monthly VOC use cutoffs are
equivalent to the proposed 25 g/tire cutoffs, as they were developed
using the same bases (production rates, etc.) that were used to determine
the proposed 25 g/tire cutoffs.  In addition, the VOC use cutoff numbers
reflect the same cost-effectiveness value as the 25 g/tire cutoff
numbers.  (See docket entry number IV-B-9 for conversion of 25 g/tire
format to monthly VOC use format.)  Furthermore, the VOC use 'format
better reflects the EPA's basis (total solvent use, regardless of the
number of tires processed) for exempting facilities that would incur
control costs judged too high for the amount of emission reduction that
would be achieved.  This format also eliminates the commenter's problem
of having to reduce emissions by 75 percent where total VOC use could
be relatively "small", but the amount of VOC applied per tire could
exceed the proposed 25 g/tire cutoff.
     The monthly VOC use cutoff figure would depend on whether a calendar
month schedule or "4-4-5" week production schedule is used for compliance
and the number of days in a calendar month (see Section 2.6.1 of this
document for discussion on definition of month).  Where VOC use at each

                                  2-13

-------
undertread cementing facility is equal  to or less than the following
monthly cutoffs, 75 percent emission reduction is not required at that
facility:

Number of Days Per Month              VQC Use Limit
       28                           3,870 kilograms (kg)
       29                           4,010 kg
       30                           4,150 kg
       31                           4,280 kg
       35                           4,840 kg (for 5-week  production
                                             months only).
Where VOC use at each sidewall  cementing facility is equal to or less
than the following monthly cutoffs, 75 percent emission reduction is
not required at that facility:
Number of Days Per Month           VOC Use Limit
         28                         3,220 kg
         29                         3,340 kg
         30                .         3,450 kg
         31                         3,570 kg
         35                         4,030 kg (for 5-week  production
                                             months only).
     VOC use cutoffs also have  been included for green tire spraying
operations that use organic solvent-based sprays.  These  cutoffs are
discussed in Section 2.4.8.1 of this document.
     B.  Method of Counting Tires — Bead Cementing, Tread End Cementing,
     and Green Tire spraying Operations that Use Water-Based Sprays
     The standards for bead cementing operations, tread end cementing
operations, and green tire spraying operations that use water-based
sprays require tire manufacturers; to maintain VOC emissions from these
operations at or below the levels; selected as representative of BUT.
VOC consumption and tire production data supplied by the  industry
indicated that, on the average, VOC emissions of 10 g/tire or less for
tires receiving tread end cement and emissions of 5 g/bead or less for
beads receiving cement are achievable (see Section 2.2.1  and 2.1.2 of
this document for further discussion of bead cementing and tread end
cementing).  The data also show that VOC emissions of 1.2 g/tire or less

                                 2-14

-------
for tires receiving water-based  inside green tire sprays  and  emissions
of 9.3 g/tire or less for tires  receiving water-based outside green tire
sprays are achievable.  Cotranenters have not provided information indica-
ting that these levels are not achievable.  Consequently,  T0  for bead
cementing, tread end cementing,  and water-based green tire spraying will
remain as the number of tires or components receiving an  application of
cement or spray.
2.4.2  Bead Cementing Limits
Comment:
     Two commenters (IV-D-1, IV-D-6) implied that plants  producing
certain types of tires having more than two beads per tire would be
covered by the proposed standards, and would not be able  to meet the
10 g/tire limit of §60.542(a)(4).  Tires requiring more than  two beads,
which would be covered by the proposed NSPS, are types which  must meet
high weight loading requirements, such as LUV pickup tires, implement
tires, bulldozer trailer tires, space shuttle tires, and  some other
12-ply tires.  One commenter (IV-D-1). noted that the proposed definition
of T0 for bead cementing is the total number of beads to  which cement
is applied, divided by 2.  The commenter felt this definition indicates
the assumption that each tire to be covered by the NSPS has two beads.
The commenter then stated that the proposed definition of T0, in
conjunction with the 10 g/tire limit therefore actually represents a
b g/bead emission limit.  This commenter stated there is  no problem
with §60.542(a)(4) if the VOC emission limit is defined as 5  g/bead,
rather than 10 g/tire.
Response:
     The EPA agrees with the commenter (IV-D-1) that the  proposed 10 g/tire
limit for bead cementing is based on the assumption that  all  tires to
be covered by the standards would be produced with two beads  per tire.
Information obtained by the EPA from the tire industry during development
of the proposed standards indicated that two beads were used  in producing
each tire to be covered by the NSPS.  VOC use data were provided by
industry on a per bead basis (see docket entries II-D-126, II-D-130,
II-D-132, II-D-133, II-D-136-140, II-D-144, II-0-145, II-D-156).  The
gram per tire VOC use factors for each plant consequently were calculated
by multiplying the gram per bead factors by 2.  These gram per tire VOC

                                 2-lb

-------
use factors ultimately demonstrated that the majority of plants,  and at
least one plant in each company supplying data, used 10 grams or  less
VOC per tire, or 5 grams or less VOC per bead, to cement beads for
tires which would be covered by the NSPS.
     Information provided after the public hearing (IV-D-1,  IV-D-6) has
established that more than two beads per tire are required for certain
high weight load bearing tires which will be covered by the  standards.
Consequently, the EPA has concluded that a 1U g/tire limit is not techno-
logically feasible for plants producing tires having more than two beads.
The emission limit for affected bead cementing facilities therefore has
been revised to 5 g/bead.
2.4.3  Absorption of VOC
Comment:
     Two commenters (IV-D-1, IV-3-5) expressed concern that absorption of
VOC by rubber is not reflected in the proposed standards.  One commenter
(IV-0-5) also stated that the overall control efficiency for an affected
facility should be based upon the quantity of VOC available for capture
and that the absorption factor does not  appear in the calculations for
determining  system efficiency.  Both commenters stated that the quantity
of VUC not  immediately available for capture probably was substantially
higher than  the 8 percent figure assumed by the EPA.  The commenters
referenced  a report by TRC,  Inc. (docket entry number II-A-39) to support
their statements.
Response:
     The absorption of VOC  into rubber  stock was  taken  into account by
the  EPA  in  selecting the  percent emission reduction  requirements  in the
standards.   These  requirements could have been expressed either as a
percent  of  the  total VOC  used, or  as a  percent of the VOC available for
capture  (i.e.,  that VOC which  is not absorbed  into  the  rubber).   If the
percent  of VOC  available  for capture format  had  been  chosen,  a procedure
that subtracts  the  absorbed VOC from the total VOC  used  would have been
necessary  to determine the  quantity available  for capture.  This  would
have required  extensive  testing on the  different  types  and  sizes  of  the
tire components cemented  at each affected facility  to determine  their
absorption figures.   By  choosing the percent  of  VOC used format,  absorption
                                    2-16

-------
can be implicitly considered, and the additional  testing and calculations
can be avoided.
     The assumptions used in selecting the 75 percent emission reduction
requirement for undertread and sidewall cementing were that at least
80 percent of the VOC used could be captured and  that the control  device
could recover or destroy at least 95 percent of the captured VOC.   At
least 70 percent of the VOC used was assumed to evaporate in the cement
application area.  Of the remaining 30 percent, 90 percent was assumed
to evaporate from the rubber within 30 seconds after its application;
thus an additional 27 percent of the VOC used would be available for
capture after cement application (see BID, Section 3.2.2.1.1).  Therefore,
a total of at least 97 percent of the VOC used should be available for
capture within 30 seconds after application.  Under these circumstances,
80 percent of the VOC used could be captured.
     The TRC report referenced by two of the commenters primarily was an
investigation of the feasibility of developing a test method for measuring
absorption of VOC into rubber.  The test methodologies used were not  .
representative of actual plant conditions.   In actual practice, rubber is
not cooled and reheated  before receiving cement; the test methodology
required the rubber-samples to be reheated,  possibly affecting the amount
of solvent absorbed.  Absorption factors reported for cemented samples
that were weighed under  ventilated conditions are highly suspect because
an airflow of 100 feet per minute was directed on the cemented surface,
a condition which is unlikely to be encountered in capture systems.  The
force  of the air  impinging on the surface of the rubber samples could
inflate the actual  absorption rate value.  The TRC report also points out
that this method  of ventilation had an adverse effect on the extremely
sensitive weighing  device used.  Further, control group samples (that is,
reheated uncemented  rubber) were not weighed for comparison to the
cemented samples.
     The TRC report does appear to  indicate  that under some circumstances
more than 10 percent of  the VOC which  does not evaporate in the cement
application area  may not evaporate within 30 seconds after application.
None of the data  for unventilated samples, however,  indicate that  so
much VOC remains  on  the  rubber 30 seconds after application that
80 percent of the VOC used could not be captured.
                                  2-17

-------
     The EPA believes that the absorption of VUG  into  rubber has been
adequately accounted for in the percent emission  reduction  requirements
and that no changes to these requirements are warranted.   (Also, see
Section 2.3.2 of this document for additional information.)
2.4.4  Emission Limits for Undertread and Sidewall  Cementing
Comment:
     One commenter (IV-D-4) stated support for a  cutoff for undertread
cementing and sidewall cementing facilities of no lower than 2b g/tire.
The commenter's reason for supporting the cutoffs was:  as  solvent usaye
per component decreases, the feasibility of installing control  decreases
significantly; and control of emissions from production of  small tires,
where solvent use is correspondingly small, is not feasible.  The commenter
provided no data pertaining to feasibility of control  of emissions from
small tire production.
Response:
     No  response is necessary.
2.4.b  Emission Limits for Michelin-A, -B, and -C-Automatic Affected
       Facilities
Comment:
     One commenter  (IV-D-5) stated that solvent use rate cutoffs should
be established for Michelin-A, Michelin-B, and Michelin-C-automatic
affected facilities  to provide incentives  for the company to develop
methods  of utilizing  low  solvent and no solvent technologies.  Cost data
to support such cutoffs previously were provided to the EPA.  Additional
cost information was  provided with these comments on the proposed regulation;
these  attachments  have been placed in  the  project confidential  files.
Response:
     As  stated in  the preamble to the  proposed standards, the VOC use
cutoffs  were  provided to  exempt,  from  the  specific emission  reduction
requirements  of  the  standards, those facilities where the control costs
were judged  to be  too high  for the emission  reduction achieved.  Based
on the  uncontrolled  emission  rate data and  on the control cost data
provided by  Michelin for  its  three unique  facilities, the cost
effectiveness of  the proposed  standards  for  Michelin  facilities  was
judged  by  the Administrator to  be reasonable.  Consequently, there  is
no need for  the  EPA to  determine and to  provide  VOC use  cutoffs  for  the

                                  2-18

-------
Michelin facilities.  However, given Michelin's stated intent to reduce
VOC use at new facilities, the EPA recognizes that there may be a VOC
use rate (at such new facilities) where the costs per ton of VUG removed
would exceed the costs determined by the Administrator to be reasonable.
     More detailed information on the design and cost of the emission
reduction systems which the commenter believed would be necessary to
meet the proposed percent emission reduction requirements at Michelin-A,
Michelin-B, and Michelin-C-automatic operations were received after
proposal (see docket entry number IV-U-12).  After reviewing this
information and conducting an independent cost analysis (see docket
entry number IV-B-lb) at various levels of VOC use, the Administrator
has decided to include total monthly low VOC use cutoffs in the final
standards for these three types of affected facilities.  These cutoffs
are based upon the cost, including credits for recovered VOC, of using
a carbon adsorber to control VOC emissions from a single affected
facility.  The cutoffs exempt from the percent emission reduction
requirement those affected facilities where the cost of VOC emission
control would be disproportionate to the emission reduction achieved.
The cutoffs are equivalent to 12.5 g/tire at Michelin-B operations and
15 g/tire at .Michelin-A and Michelin-C-automatic operations.
     The total monthly VOC use cutoff figure would depend on whether a
calendar month or a "4-4-5" week month is used for compliance and the
number  of days in a calendar month (see Section 2.6.1 of this document
for discussion on definition of month).  Where VOC use at each
Michelin-A, or -C-automatic facility is equal to or less than the
following monthly cutoffs, 65 percent emission reduction is not required
at that facility:

Number  of Days Per Month              VOC Use Limit
        28                           1,570 kilograms (kg)
        29                           1,630 kg
        30                           1,630 kg
        31                           1,740 kg
        35                           1,970 kg (for 5-week production
                                             months only).
                                  2-19

-------
Where VOC use at each Michelin-B  facility is equal  to  or less than the
following monthly cutoffs, 75 percent emission reduction is  not required
at that facility:

Number of Days Per Month              VOC Use Limit
       28                           1,310 kiloyrams (kg)
       29                           1,360 kg
       30                           1,400 kg
       31                           1,450 kg
       35                           1,640 kg (for 5-week production
                                             months only).
2.4.6  Emission Limits for Undertread Cementing and Sidewall  Cementing
Comment:
     One commenter (IV-D-2) suggested that the proposed standards for
undertread cementing and sidewall cementing be changed, by  deleting
§§60.542(a)(i) and (1i) and replacing them with "(i) 25 grams of VOC
per tire processed for each calendar month or 25 percent of  the VOC
used (75 percent emissions reduction, whichever is greater)."  The
commenter supported his suggestion by writing that the change still
would  require installation of capture and control systems where large
amounts of VOC are used but would provide relief to small emitters.
Response:
     The proposed 25 g/tire cutoffs were based on the level  of VOC
consumption  below which the Administrator judged annual ized  costs to be
unreasonable  for 7b percent emission reduction.  This approach reflects
the requirement of Section 111 of the Clean Air Act to promulgate
standards that reflect the application of the best system of continuous
emission reduction.  The commenter's suggestion would allow a manufacturer
whose  undertread cementing or sidewall cementing facility emits between
25 and  100 g/tire to install VOC emission reduction systems that are
less than 75 percent efficient,  even though the EPA has shown that the
cost of 75 percent reduction is  reasonable.  The commenter's suggested
revision, therefore, would permit the use of controls which are not the
best  system  of continuous  emission  reduction, and would  be contrary to
the  requirements of  the Clean Air Act.   Furthermore,  because the cutoffs
now are expressed in terms of total  VOC  use  (see Section 2.4.1 of  this

                                  2-20

-------
document), the EPA believes that the cutoffs are appropriate for small
emitters.
2.4.7  Percent Emission Reduction Requirements
Comment:
     One commenter (IV-D-2) stated that the 75 percent emission reduction
requirements for undertread cementing and sidewall cementing facilities
are unrealistic.  One reason cited was that the only emission reduction
system currently in operation achieves an overall efficiency of about
63 percent.  The commenter also stated that some facilities that use
only a small amount of VOC per tire could have trouble achieving
75 percent emission reduction.  The commenter provided a theoretical
example to support this claim.
Response:
     The 75 percent emission reduction requirements for undertread and
sidewall  cementing were set based on the EPA's conclusion that at least 80
percent of the VOC used could be captured and sent to a control device
that would destroy or recover at least 95 percent of the captured
VOC.  The emission test data referenced by the commenter are for a
retrofitted undertread cementing emission reduction system.  This
system is one of only two such systems known to exist.  No test data
are available for the second system.
     The available emission test data show short-term overall VOC
emission reduction efficiency of about 67 percent (docket entry number
II-A-28).  Available long-term materials balance calculations indicate
an emission reduction efficiency of 63 percent (docket entry number
II-A-13).  Section  4.3.1 of the BID and the preamble to the proposed
standards outlined operational and design problems cited by the operator
of the retrofitted control system which he cited as reasons for reduced
efficiency.  Among the problems cited by the operator, the EPA found
the following factors to most significantly affect the control system's
performance:
     1.  VOC was emitted from undertread cement application equipment
         over weekends and holidays when the line and emission reduction
         system were not operating.  This problem can be mitigated by
         placing tight fitting covers over the equipment when not used
         for extended periods.  The amount of solvent estimated to be
         used by undertread cementing therefore was greater than
         actually would be used during normal operating periods.

                                  2-21

-------
     2.   VOC losses from solvent,  and  cement  storage  tanks  in  the  cement
         house were included  in  total  solvent  consumption  calculations
         for undertread cementing.  These  losses  inflated  actual  VOC
         use values for the the  facility.
     3.   Vent dampers  were not  equipped  with vapor loss  seals,  which
         reduced the amount of  VOC  available to the  carbon adsorber.
     4.   Carbon beds were not adequately cooled and  dried.  Adsorber
         VOC removal efficiency  consequently was  impaired  (see  Section
         2.3.2 of this document  for full discussion  of reasons  why  the
         efficiency of this carbon  adsorber  was impaired).
     5.   VOC recovered by the carbon  adsorber  was lost because  of
         improper decanter design,  thereby misrepresenting the  actual
         reduction efficiency of  the  system.
     6.   Improper installation  of the end  flap on the drying  conveyor
         enclosure allowed VOC  to escape from  the capture  system  and
         consequently reduced the amount of  VOC available  to  the  carbon
         adsorber.

The EPA believes that by correcting the  problems  outlined  above,  the
overall  capture efficiency can  be increased  to at least  80 percent  of
total VOC used and consequently  the emission reduction efficiency of
the system can be increased to  at -least  75 percent.
     In  his "small" VOC user  example, the  commenter assumed that  exactly
80 percent of the VOC that evaporates in the cement  application area
and in the first 30 seconds after cement application would be captured.
This resulted in an overall capture of less  than  80  percent of  the
total VOC used, since not all of  the  VOC used  evaporates within 30
seconds after cement application.  The commenter  then concluded that
the "small" VOC user could not  achieve an  overall 75 percent  emission
reduction, even when using a  96  percent  efficient control  device.
     In contrast to the commenter's assumption, however, the  EPA  has
concluded that 80 percent of  the  total VOC used could be captured.   Of
the 38.2 g/tire applied by the "small" VOC user,  the commenter assumed
that 19.2 g/tire would evaporate in the  cement application area,  and
17.1 of the  remaining 19.0 g/tire would  evaporate within 30 seconds,
after cement application.  Of the 36.3 g/tire  which evaporate, and
therefore are available for capture,  30.6  g/tire  (84.3 percent of
the available VOC) would have to be captured to achieve 80 percent
capture of the total VOC used.   The EPA believes  this capture efficiency
is achievable through the measures  discussed at proposal and above.

                                   2-22

-------
By venting the captured VOC to a 95 percent efficient control device,
75 percent overall  emission reduction would be achievable.  Therefore,
no change has been made to the percent emission reduction requirements
for undertread cementing and sidewall cementing facilities.
2.4.8  Green Tire Spraying
     2.4.8.1  Organic Green Tire Spraying Emission Limits.
Comment:
     Two commenters (IV-F-1, pp. 9-11; IV-U-9) requested that the
proposed standards for inside and outside green tire spraying be
revised to include provisions for use of organic solvent-based green
tire sprays.  One commenter was concerned that the proposed standards
assume that all affected green tire spraying operations can use water-
based sprays and that the proposed emission limits (1.2 g/tire for
inside sprays, 9.3 g/tire for outside sprays) are significantly more
stringent than could be achieved by using organic solvent-based sprays
in conjunction with the best capture and control devices.
Response:
     The proposed standards for inside and outside green tire spraying
were based on industry-supplied information indicating that water-based
sprays were replacing organic solvent-based sprays at most operations.     • .
While the EPA still believes that use of water-based sprays will predominate,
it recognizes that organic solvent-based green tire sprays must be used
in some cases.  Consequently, a standard of performance has been developed
for green tire spraying operations where organic solvent-based sprays
are used.  The EPA has determined that 75 percent emission reduction, based
on 80 percent capture and 9b percent control, represents the best system
of continuous emission reduction for organic solvent-based green tire
sprays.  Accordingly, the standard requires a 75 percent emission
reduction at a facility where VOC use from organic solvent-based sprays
exceeds the monthly cutoffs.  In addition, an alternative compliance
method is provided.
     The following monthly total (uncontrolled) VOC use cutoffs (see
docket entry number IV-B-9) represent the combined VOC use rate for
organic solvent-based inside and outside spray applications below which
the cost to reduce VOC emissions by 75 percent from a single green tire
                                  2-23

-------
spraying facility has been judged unreasonable for the emission reduc-
tion achieved:
Number of Days Per Month           VOC Use Limit
           28                           3,220 kg
           29                           3,340 kg
           30                           3,450 kg
           31                           3,570 kg
           35                           4,030 kg (for 5-week production
                                        months only;  see Section 2.6.1
                                        of this document for discussion
                                        on definition of month).
Costs used to develop the cutoffs were based upon a retrofit situation,
where VOC emissions captured in an enclosed booth are vented to a
baghouse for particulate removal  and then to a carbon adsorber for
recovery.
     Equipment requirements are provided as an alternative means of
demonstrating compliance with the standards for VOC-based green tire
spray facilities (see Section 2.4.8.2 of this document).
     2.4.8.2  Alternative Compliance Method for Organic Solvent-Based  •
Green Tire Spraying.
Comment:
     Four commenters (IV-U-1; IV-0-4; IV-9; IV-F-1, pp. 9-11) requested
that the EPA provide an alternative compliance method for plants that must
use organic solvent-based green tire sprays.  Limited supporting infor-
mation was provided which showed that some tire plants must use organic
solvent-based sprays to manufacture certain types of tires.  Some plants
that had converted to water-based sprays have had to return to use of
organic solvent-based sprays for production of some tire types.  The
commenters also wrote that the proposed numerical emission limits
reflect an assumption that water-based sprays will be used at all
operations, and that these limits cannot be achieved where organic
solvent-based sprays are employed, even when using the best capture and
control equipment.  One commenter (IV-D-1) suggested that the alternative
compliance method for green tire spraying facilities where organic
solvent-based green tire sprays are used should be similar to the
alternative compliance method for undertread cementing and sidewall

                                  2-24

-------
cementing facilities [§6U.b43(h)].  However, these alternative methods
should not be identical since some spray constituents form solid particles
which require different control  measures.  No additional  information
concerning particle formation was provided.
Response:
     The EPA is including equipment requirements as an alternate method
of demonstrating compliance with the standards for green  tire spraying
operations.  This alternative compliance method is similar to that
included in the alternative compliance method for undertread cementing
and sidewall cementing [§60.543(j)].
     Under the alternative compliance method, the owner or operator of
an affected green tire spraying facility can seek to demonstrate compliance
with the standards for yreen tire spraying facilities where organic
solvent-based sprays are used by meeting the following design and
equipment requirements:

     1.  Enclosure (i.e., the capture system) of spray application and
         drying areas.
     2.  1UO feet per minute (fpm) face velocity through  all permanent
         openings in the capture, system.
     3.  Coated green tires retained in capture system for at least
         30 seconds.
     4.  The total area of all permanent openings into the enclosure
         does not exceed the area necessary to maintain the VOC
         concentration of the exhaust stream at 25 percent of the lower
         explosive limit (LEL) when the facility is operating at its
         maximum solvent use rate, the face velocity through all
         permanent openings is 100 fpm, and all temporary openings are closed,
     b.  Captured VOC vented to a 95 percent efficient control device.

The 1UO fpm face velocity requirement for all permanent openings and
the 30-second retention time requirement for coated green tires are to
assure optimal capture of VOC.  The purpose of the maximum permanent
opening area requirement is to minimize the escape of fugitive emissions
from the enclosure.  Twenty-five percent of the LEL was selected as the
reference point for sizing permanent-openings because it  represents the
level  of dilution most commonly used to avoid fire and explosion hazards.
Ninety-five percent control of captured VOC is required as this is consi-
dered best demonstrated technology (see Section 2.3.3 of  this document).

                                  2-25

-------
A particulate removal  device, such as a scrubber, a filter, cyclone, or
baghouse, may be needed in some cases to pretreat the green tire spray
exhaust stream prior to its entering the VUG control  device in order to
avoid fouling of the VOC control  device by particulates in the green
tire overspray.  However, exhaust stream pretreatment for particulate
removal is not required by these  standards.
     2.4.8.3  Proposed Water-Based Green Tire Spray Emission Limits.
Comment:
     One commenter (IV-D-4) stated that the proposed  regulations for
green tire spraying [§6U.542(a)(5) and (6)] are acceptable when water-based
sprays can be used.
Response:
     No response is necessary.
2.5  COMPLIANCE BUBBLE
2.5.1  Bubble Considerations
Comment:
     Most of the comrnenters (IV-D-1, IV-D-3, IV-D-4,  IV-0-5, IV-D-b,
IV-U-7, IV-D-8) requested that a general bubble provision.be .added
to the standards before promulgation.  The commenters believe that a
bubble is appropriate for this industry because there is a large number
of small affected facilities, and they claim that the cost of capture
and control technology may vary widely from facility to facility.  A
bubble provision would allow the industry to reduce further emissions
at those facilities where it is least costly in exchange for avoiding
control at facilities where it is more costly.  The commenters state
that the control flexibility provided by a bubble would provide the
potential for  large cost savings to the industry.  Two specific examples
of how a compliance bubble could result in cost savings were provided
(IV-D-6, IV-D-8).  One commenter proposed a trade of emissions between
an undertread  cementing facility and a tread end cementing facility.
The uncontrolled VOC emissions from the facilities would be 63 g/tire
and 15.1 g/tire, respectively.  The commenter used the proposed 25 g/tire
VOC use cutoff  level as the emission limit for the undertread cementing
facility and combined that level with the 10 g/tire limit  for tread end
cementing for  a bubble limit of 35 g/tire.  The commenter  would install
a 75  percent efficient capture and control system at the undertread

                                 2-26

-------
cementing facility to reduce emissions to 15.7 g/tire.  The 15.7 y/tire
emission rate combined with the uncontrolled emission rate of lb.1 g/tire
at the tread end cementing facility (15.7 + 15.1 = 30.8) would be less
than the commenter's 35 g/tire bubble limit, thereby allowing the
manufacturer to avoid reducing emissions from the tread end cementing
facil i ty.
     Commenter IV-D-8 urged the Agency to consider a bubble that would
allow a plant owner/opera tor to obtain emission credits for operations
that are not performed at a particular tire plant.  This commenter's
company no longer cements beads as part of the manufacturing process
and wants to obtain credit equal  to the 10 g/tire bead cementing limit
for use at another facility (presumably to avoid installing a control
system at an undertread cementing or sidewall cementing facility).
Response:
     The bubble suggested by commenter IV-D-6 used the proposed
25 g/tire VOC use cutoff (now revised to a monthly VOC use level) as
an allowable emission level for an undertread cementing facility that
uses a capture/control system, instead of the 15.7 g/tire level that
would be required by the standards (75 percent reduction from the
uncontrolled level of 63 g/tire).  Under the facility-by-facil ity
standards, the combined emissions from undertread cementing and tread
end cementing would be, at most, 25.7 g/tire (15.7 + 10 = 2b.7); under
the commenter's proposed bubble, the emissions would be 30.8 g/tire, or
at least 5 g/tire greater than the emissions under the facility-by-facility
application of the standards.  If this plant were a medium-sized plant
producing 30,000 tires per day, the 5 g/tire increase would result in a
total emissions increase of about 50 tons per year.
     Furthermore, the commenter's use of the VOC use cutoff numbers
as emission limits for facilities with capture/control systems is a
misapplication of the cutoffs.  The cutoff numbers represent a VOC use
rate where the costs of operating a capture/control system were judged
to be too high for the emission reduction achieved; that is, if a
facility used only 25 g/tire or less, no further emission reduction
would be required.  However, facilities using more than 25 g/tire were
required to reduce emissions by 75 percent because the costs are
reasonable for these facilities.  Thus, the commenter is applying the

                                  2-27

-------
wrong emission limit to undertread cementing,  since his uncontrolled
level is 63 g/tire.
     The second example (from commenter IV-D-8) proposed to allow a
plant owner/operator to obtain emission credits for operations that are
not performed at a particular tire plant.  This commenter no longer
cements beads as part of the manufacturing process and wanted to obtain
credit equal to the 10 g/tire bead cementing limit for use at another
new facility  (presumably to avoid installing BDT controls at an undertread
cementing or sidewall cementing facility).
     The approach of generating emission reduction credits from avoiding
construction of certain emitting facilities would not be permitted
where the credits would clearly result in increased emissions.  If
credit were given for production facilities that have not been built,
other facilities that have been built might not need to install tJOT.
For example, if the 5 g/bead limit for bead cementing (again, this
figure is equivalent, in most cases, to 1U g/tire) in the commenter's
proposal were given as a credit to be applied elsewhere, emissions from
the plant could be 10 g/tire higher under a bubble than they would be
under the facility-by-facility standards.
     For the  reasons discussed above, the Agency has not provided a
generic NSPS compliance bubble in the standards.  However, the Agency
has  recently approved an NSPS bubble application  (b2 FR 28946).  In
doing this, the Agency made clear that we will receive case-by-case
applications  for NSPS compliance bubbles.  The major factors that will
influence decisions on whether to approve them were also described.
The Agency  will consider bubbles for rubber tire manufacturing
facilities  on a case-by-case basis in accordance with such factors.
2.5.2  Affected Facilities
Comment:
     One commenter  (IV-D-7) suggested that, if the compliance trade-off
was  not sufficiently flexible, that the EPA should redefine  "affected
facility" more  broadly so that a company could implement changes with
no net increase in emissions.  This commenter  also stated that with the
proposed narrow definition, almost any equipment  change  likely would
be considered construction  of a new source or  modification.
                                   2-28

-------
Response:
     The purpose of Section 111 of the Clean Air Act is to minimize
emissions by application of BDT at all new and modified sources.   A
narrow designation of an affected facility therefore is presumed  to
ensure that new emission sources will  be subject to the standards as
they are installed.  As stated at proposal, this presumption can  be
overcome and a broader designation of an affected facility used when
the broader designation would yield greater emission reduction, equal
emission reductions at lower cost or other impact, or lesser reductions
at such a low cost that the incremental  cost of using a narrow designa-
tion is exorbitant.  The commenter, however, offered no supporting
evidence indicating that a broader designation of an affected facility
is appropriate under this test.
     Furthermore, assuring extra flexibility to the industry is not a
goal or a factor to be considered when determining BDT under Section
111 of the Clean Air Act.  Selecting BDT requires only consideration of
emission reduction cost and nonair quality health, environmental, and
energy impacts.  These factors have been adequately considered by the
EPA in developing the standards.
2.6  PERFORMANCE TEST METHODS AND MONITORING
2.6.1  Definition of Month
Comment:
     Several commenters (IV-D-1, IV-D-6, IV-D-8) stated that some tire
manufacturers use a cycle closing calendar based on "4-4-5 week"  months
which would make it extremely difficult for these companies to conduct
performance tests each calendar month.  The "4-4-5 week" month cycle
consists of two 28-day (4 week) months and one 35-day (5 week) month
per quarter year.  The "4-4-5 week" month system is employed by at
least one commenter1s company to provide a uniform system of statistical
analysis for all accounting, production, and marketing (IV-0-8).   The
commenters offered no details of problems expected to be encountered
in switching from a "4-4-5 week" month to a calendar month system for
performance test purposes.
Response:
     The EPA feels that the results of performance tests that are
conducted using averaging times of 28, 30, or 35 days are essentially

                                  2-29

-------
the same.  The EPA therefore has no objection to companies  making
compliance calculations, as are required by the performance test
provisions, in a manner compatible with company accounting  records.
      The EPA has defined "month" in §60.541 to be a calendar month or
a period of 28 days or 35 days.  By this definition of month, companies
that employ a "4-4-5 week" month cycle closing calendar will  be required
to conduct performance tests by the 28th day, 56th day, and 91st day of
each quarter year or some other combination of two 4-week and one
5-week intervals.  At the initial  startup of an affected facility,  each
plant's owner or operator will  be required to specify in an initial
report to the Administrator the monthly interval  at which performance
tests will be conducted.
2.6.2  Monthly Performance Testing
Comment:
     Two commenters (IV-0-1, IV-D-6) wrote that monthly performance
testing is neither necessary nor appropriate.  One commenter (IV-D-1)
cited performance test provisions of the NSPS for the publication roto-
gravure printing industry (40 CFR 60,433) and the proposed  standards
for the petroleum dry cleaning industry (§60.624) as precedent for
dropping the monthly performance test requirements.  This commenter
also wrote that an affected rubber tire facility which is shown to  be
in compliance by an initial performance test is no more or  no less
likely to fail to comply at a later date than an affected facility  in
any other industry.  Both commenters (IV-0-1, IV-D-6) also  contended
that most of the data required for monthly performance tests are not
routinely collected and maintained by every company and that the monthly
performance test requirements would impose undue burdens on most plants.
Response:
     Routine performance testing assures compliance with the standards
on a continuous basis, for example, by assuring that control  equipment
is operated and maintained properly.  Routine testing is required for
NSPS wherever it is technically feasible and the cost, or labor burden,
is judged reasonable.
     The  reasons the EPA did not require monthly performance tests  in
the rotogravure NSPS and proposed petroleum dry cleaning NSPS are not
relevant to the decision to requi re monthly performance tests in the

                                  2-30

-------
standards for rubber tire manufacturing.  Monthly performance test
provisions were dropped from the rotogravure NSPS because of problems
associated with measuring ink temperature and in calibrating and opera-
ting the large number of ink flow meters that would have been required
to determine the volume of solvent used (see Rotogravure BID Volume II,
£PA-450/3-80-031b, Sections 2.6.1-2.6.3, 2.6.5).  As discussed above,
the standards do not require temperature correction factors or flow
meters.  Monthly performance testing was not required in the petroleum
dry cleaning NSPS because calculations showed that the costs of such
testing would be unreasonably high.
     Monthly performance tests required by the standards are simple
materials balance determinations.  The standards do not require the
more complex and costly stack measurement tests, installation of flow
meters, or. application of temperature correction factors.  The labor
burden of monthly performance tests and recordkeepi ng requirements also
are judged to be reasonable.  The average industry-wide burden of the
performance test and recordkeepi ng requirements over the first 5 years
of the standards would be about 5,700 person-hours (.2.75 person-years)
per year (docket entry number IV-B-6).  The EPA therefore has concluded
that monthly performance testing is necessary and appropriate to ensure
compliance with the standards on a continuous basis.
2.6.3  Temporary Total  Enclosure for Incinerators
Comment:
     One commenter (IV-0-2) suggested that where a control  device is
employed which destroys VOC, a better method of determining compliance
during the performance test would be to measure the  amount  of VOC
removed by the control  unit and divide the amount by the quantity of
VOC used  during the test.  A total  enclosure for performance testing
of emission reduction systems that destroy VOC [§60.543(d)(2)(i)]
probably would produce results different from those  produced under
actual operating conditions and construction of a "total" enclosure
probably  would be impractical.
Reponse:
     The  commenter's suggested approach in determining compliance for
emission  reduction systems  that use incinerators is  infeasible due to
difficulties with making direct comparisons  between  the  test results for

                                  2-31

-------
    content of liquids under Metliod 24 and the test results for VOC
content of gases under Method 25.  Unlike Method 24, Method 25 measures
total  carbon in the gaseous phase, which can include compounds other
than VOC.  Consequently, Method 25 can show that more VOC is captured
                            <-.
in the gaseous phase than actually is available from the liquid phase.
     The EPA therefore considers the method used in §6U.b43(f) and (g) to
be the best available for determining overall  emission reduction efficiency
of control systems that employ incinerators.  With these procedures,
the overall emission reduction efficiency of the control system (R) is
ascertained by multiplying the gaseous fraction of total VOC used which
enters the control device (F0) (i.e., the capture efficiency)  and the
destruction efficiency of the control device (E).
     Although the term "temporary total  enclosure" was used in a practical
engineering sense, a literal interpretation of this term could lead to
both compliance and enforcement problems.  Literal interpretation of
"temporary total enclosure" could impose performance test conditions that
would be difficult to achieve when determining the fraction of total VOC
used which enters the control device.  In view of this possibility, the
EPA has changed the wording of §60.543(f)(2)(i) to require that during a
performance test, a temporary enclosure be constructed and operated at a
negative pressure to ensure that all evaporated VOC is measurable.
2.7  ALTERNATIVE COMPLIANCE METHODS
2.7.1  General
Comment:
     Three commenters (IV-F-1, IV-D-1, IV-D-4) specifically supported
the inclusion of an alternative compliance method for undertread cementing
and sidewall cementing, saying the proposed method is technically sound
and necessary.
Response:
     No  response  is necessary.
2.7.2  Capture System Design Criteria
Comment:
     Two  commenters (IV-D-1,  IV-0-5) implied that they supported the use
of  alternative compliance methods and wrote that the proposed alternative
compliance method should be  flexible concerning capture system design
criteria.  The commenters wrote that because capture systems must be

                                  2-32

-------
designed according to the requirements and configurations of a particular
operation, the VOC capture will  vary with individual  process variables.
One commenter (IV-D-1) supported the alternative compliance method require-
ment that a 10U fpm minimum face velocity must be maintained through each
permanent opening in the enclosure.  This commenter also felt that the
alternative compliance method provision which requires enclosure of the
undertread cement and sidewall  cement drying areas for 30 seconds after
cement application or to the water bath, whichever distance is less, is a
good example of the flexibility  needed to meet the proposed standard.
The other commenter (IV-D-5) suggested that the proposed alternative
compliance method be changed to  allow for suspension  of drying area
enclosure retention time limits  where tire components must be moved to
another location, have other components applied to them, or where there
is some other occurrence that would make it impractical  to retain these
components in an enclosure for the required time limits.  This commenter,
however, provided no information supporting the request to suspend time
limits under certain circumstances. •
Response:
     The EPA based the capture system requirements of the alternative
compliance method on good engineering practices, VOC  emissions data, and
process design information provided by the tire industry.  The EPA con-
siders the 30-second retention time requirement necessary to assure
80 percent capture and 75 percent overall emission reduction.  Without
this assurance, the EPA cannot waive the requirement  for performance tests
in accordance with §60.8(b)(4)  of the General  Provisions.  Consequently,
the EPA has not changed the alternative compliance method.
2.7.3  Alternative Compliance Methods for Affected Facilities Other
       Than Undertread Cementing, Sidewall Cementing, and Michelin-8
       Facilities
     2.7.3.1  Comment:
     One commenter (IV-Q-b) requested that all compliance methods and
particularly the alternative compliance method be made available for
each type of affected facility.   The commenter wrote  that some affected
facilities currently are not adaptable to all  compliance alternatives,
but future changes could make alternatives more attractive, economical,
and environmentally sound.  The  commenter felt that exclusion of some

                                   2-33

-------
affected facilities could hinder development that could have potentially
beneficial impacts on its company, the industry, and the environment.
Response:
     Alternative compliance methods are provided in the promulgated
standards for undertread cementing, sidewall cementing, and Michelin-B
facilities.  An alternative compliance method for affected green tire
spraying facilities where organic solvent-based sprays are used also is
included (see Section 2.4.8.2 of this document).  Compliance of affected
bead cementing and tread end cementing facilities with the standards
would be demonstrated in most cases by determining the mass of VOC used
per component processed, since, in the EPA's view, installation of
capture and control technology would not be necessary.
     The EPA has concluded that it cannot establish an alternate
compliance method for Michelin-A and -C-automatic facilities.  In
determining BDT for Michelin-A and -C-automatic operations, the EPA
recognized that it was necessary to assume certain modifications to the
capture system that was assumed for undertread cementing operations,
sidewall cementing operations, and Michelin-B operations.  Michel in
indicated before proposal that the capture systems at Michelin-A and
-C-automatic facilities would have.to have a larger area of openings to
accommodate the movement of tires and associated equipment into and
away from the cementing stations.  Because of the increased open area,
the efficiency of this capture system would be less than the 80 percent
efficiency achievable at undertread cementing, sidewall cementing, and
Michelin-B operations.  Based on the EPA's evaluation of the information
provided  by Michel in before proposal and on the EPA's knowledge of
capture  systems applicable to undertread cementing and sidewall cementing
operations, the EPA determined at proposal that 7U percent capture
efficiency is achievable at reasonable costs at Michelin-A and -C-automatic
operations.  A range of costs for this modified system was assumed and
was judged to be reasonable.  Michel in indicated before proposal of the
standards  that a 6b percent overall emission reduction efficiency,
based on  a 70 percent efficient capture system and a 95 percent efficient
control  device, was achievable  at  reasonable costs at Michelin-A and
-C-automatic operations.
                                 2-34

-------
     Before the standards were proposed, Michel in provided the EPA with
a description of the capture system (including operating parameters,
such as flow rate velocity) being used at an existing Michel in-A
operation.  This system, which Michelin^. believes will achieve 7U percent
capture, is unlike the enclosures evaluated by the EPA.  Additional
information that Michelin submitted after proposal indicated that its
capture system for -C-automatic facilities is also unlike those evaluated
by the EPA.  While the EPA is confident that 7U percent capture can be
achieved at Michelin-A and -C-automatic facilities, based on the reasoning
described in the previous paragraph and Section 2.3.1 of this document,
the EPA is not satisfied that the system suggested by Michelin for use
at its -A and -C-automatic facilities is equivalent to the system the
EPA believes represents BOT.  In accordance with §6U.8(b)(4)  of the
General Provisions, the EPA may waive the requirement for performance
tests only if the owner or operator has demonstrated to the Administrator's
satisfaction that the system in question would bring the affected
facility into compliance with the standard.  Because the Administrator
is not satisfied that Michelin-A and -C-automatic facilities  can comply
with the standards using systems like those at Michelin's existing
facilities, the EPA cannot rely on those systems as a basis for waiving
the performance test requiranents.  Moreover, the EPA need not initiate
the process of listing the specific parameters of a BUT-level capture
system in the NSPS for purposes of providing Michelin a §60.8(b)(4)
waiver option.  For these reasons no alternative compliance method is
being provided for Michel in-A and -C-automatic facilities.
     2.7.3.2  Comment:
     One commenter (IV-D-7) believes that the proposed standards may be
economically unreasonable or technologically infeasible when  applied to
his company's processes and requested that the proposed rules include a
provision for an alternative compliance standard.  The commenter stated
that although the EPA has acknowledged that significant differences  in
production processes exist to the extent that different standards were
justified for one company's processes, the proposed rules do  not appear
to provide sufficient flexibility to accommodate his company's tire
production methods.
                                 2-35

-------
Response:
     The grams of VOC per tire standards reflect application of BDT at
specific affected facilities.  In instances where one  company's processes
are sufficiently different from processes generally found  in the industry,
such as Michelin-A, -B, and -C-automatic operations, the EPA has developed
separate standards of performance that reflect application of BDT at
these facilities.  The EPA, however, cannot speculate and  develop regulations
for an affected facility that does not exist at this time, particularly
where there is a lack of information about the process.
     Although the commenter claims his company has processes that could
be affected facilities if tire types within the scope of the standards
were produced, the company currently has no production facilities
operating in the U.S. that could be affected by the standards of perfor-
mance.  Except for bead cementing processes, the commenter also has
provided no specific details regarding compliance problems anticipated
by the company if it begins producing tires of the type  that would result
in any facilities' becoming suoject to the standards.
     The commenter, however, does describe problems that it expects to
encounter if its bead cementing operations are affected  by the standards.
The commenter indicated that the amount of VOC used at bead cementing
would make compliance with a 10 g/tire (revised to 5 g/bead) limit
technically infeasible.  The type of process described by the commenter,
however, does not appear to be within the scope of the bead cementing
definition, and the bead cementing limit probably would  not apply.
The commenter's process involves the cementing of a separate, all-rubber
component which is later assembled along with the bead wire.  While
more  information would be  necessary to make a determination, the process
appears  to fall within the definition of a sidewall cementing facility
and therefore would be subject to the emission limits for sidewall
cementing.  The EPA knows  of no reason why the commenter's facility
could  not comply with the  emission limits for sidewall cementing.
2.7.4  Maintenance of 25 Percent of the Lower Explosive Limit
Comment:
      One commenter (IV-0-7) wrote that with his company's solvent  usage
reduction program, it would  be difficult to maintain VOC concentrations
                                   2-36

-------
in the emission reduction systems at the level specified in the proposed
alternative engineering standard [§60.543(h)(4)], that is, 25 percent
of the LEL.
Response:
                                                                       *'-S"
     The alternative compliance method does not require the commenter's
company to maintain VOC concentrations in the capture system exhaust
stream at 25 percent of the LEL.  For further discussion of how the LEL
requirement applies, refer to Section 2.4.8.2 of this document.
2.8  RECORDKEEPING AND REPORTING
2.8.1  The Standards In Relation to the General Provisions
Comment:
     One commenter (IV-0-1) stated that the three classes of records
required by the proposed standards repeat requirements of the General
Provisions and, therefore, are redundant.  The three classes of records
to which the commenter refers to are: (1) records of all continuous
monitoring data; (2) records of 3-hour periods during which monitoring
shows certain specified below-average conditions; and (3) records of
all data-and computations used to calculate VOC emissions from an
affected facility.  The commenter wrote that special requirements for
maintaining solvent use records would have some merit if the monthly
performance tests were omitted.
Response:
     The recordkeeping and reporting requirements of the standards,
like similar requirements in standards of performance for other indus-
tries, clarify what the-General Provisions require.  The commenter
therefore is correct in observing that the recordkeeping and reporting
requirements repeat some of the General  Provisions'  requirements.
These provisions are repeated for purposes of clarification.  The EPA,
however, does not agree that maintenance of solvent use records has no
merit unless monthly performance tests are omitted.  The rationale for
requiring solvent use records in conjunction with monthly performance
tests is presented in Section 2.6.2 of this document.
                                  2-37

-------
2.9  MISCELLANEOUS
2.9.1  VQC Emission Factors
Comment:
     One commenter (IV-D-3) wrote that the emission factors  indicated
for undertread cementing (63.2 g/tire) and for sidewall  cementing
(41.1 g/tire) were not realistic for his company.   This  commenter
objected to the emission factors because the company felt they may be
applied to its operations at a future date.  The commenter,  in support
of his objection, wrote that it may not be possible for  a company or
plant to change its processes to reduce emissions  to an  average rate
achieved by other companies and other plants which have  different
manufacturing processes.
Response:
     The average VOC emission factors presented in BID Volume I were
used only to develop control cost, economic, and environmental impacts
of the  regulatory alternatives.  The  regulatory alternatives subsequently
were used with other information as bases for developing the standards.
The EPA therefore has not used and would not expect to use the average
VOC'emission factors to  develop standards of performance for affected
undertread cementing or  sidewall cementing facilities.
2.9.2   Sidewall Cementing Facilities
Comment:
     One  commenter  (IV-U-7)  stated that his company could not meet the
proposed  standards  for  bead  cementing  because of the unique method in
which  it  applies  the  cement.   This method involves  the  cementing  of  a
separate,  all-rubber  component which  is later assembled along with the
bead wire.
Response:
      The  proposed definition of  a  sidewall  cementing operation
 [§6U.541(a)3 has been revised to clarify  that sidewall  cementing
 is the cementing of any continuous  strip  of  material that is wrapped
 around the bead prior to tire building or is  incorporated into  the
 sidewall  of  the tire, and that it  is  not  only cement  application  to  an
 extruded strip of rubber.  The cementing  process  described  by  the com-
 menter therefore appears, without  further information,  to fall  within
 the scope of the sidewall cementing definition.

        *                           2-38

-------
TECHNICAL REPORT DATA
(Please read Instructions on the reverse before completing)
1. REPORT NO. 2.
EPA-450/3-81-008b
4. TITLE AND SUBTITLE
Rubber Tire Manufacturing Industry - Background
Information for Promulgated Standards
7. AUTHOR(S)
9. PERFORMING ORGANIZATION NAME AND ADDRESS
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 & Standards
Office of Air and Radiation
U.S. Environmental Protection Agency
Research Triangle Park, NC 27711
3. RECIPIENT'S ACCESSION NO.
5. REPORT DATE
September, 1987
6. PERFORMING ORGANIZATION CODE
8. PERFORMING ORGANIZATION REPORT N
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO.
13. TYPE OF REPORT AND PERIOD COVEREC
14. SPONSORING AGENCY CODE
EPA/200/04
15. SUPPLEMENTARY NOTES
This document presents the final environmental impact statement (EIS) for standards
of performance for the control of volatile organic compound emissions from rubber ti
mamifartiirp
    Standards  of performance for the control of volatile  organic  compounds (VOC)
    emissions  from rubber tire manufacturing facilities are  being promulgated under
    Section  111  of the Clean Air Ac.t.  These standards will  apply to newly constructed,
    mod.ified,  or reconstructed facilities in rubber tire  manufacturing  plants.   This
    document summarizes the public comments received on the  proposed standards  and the
    Agency's responses to those comments.  The document also summarizes the changes made
    to  the standards  since proposal.
17. KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS
Air Pollution
Pollution Control
Standards of Performance
Rubber Tire Manufacture
Volatile Organic Compounds (VOC)
18. DISTRIBUTION STATEMENT
Unlimited
b.lOENTIFIERS/OPEN ENDED TERMS
Air Pollution Control
19. SECURITY CLASS (This Report 1
Unclassified
20. SECURITY CLASS (This page)
Unclassified
c. COSATI Field/Group
13b
21. NO. OF PAGES
47
22. PRICE
EPA Form 2220-1 (Rev. 4-77)   PREVIOUS EOITION is OBSOLETE

-------
U S  Environmental Protection Agency
Region 5, Library (PL-12J)
77^West Jackson Boulevar.d, 12th Floor
Chicago, IL  60604-3590

-------