vvEPA
          United States
          Environmental Protection
          Agency
         Office of Air Quality
         Planning and Standards
         Research Triangle ParkNC 27711
EPA-450/3-82-0016
June 1990
          Air
Air Oxidation
Processes in
Synthetic Organic
Chemical
Manufacturing
Industry--
Background
Information for
Promulgated
Standards
 Final
 EIS
                           5,Ubrtry  .   .^ ^_
                        7? We«t Jackson Boulevard, 12ttl rim
                           tt 60604-3590

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                         EPA-450/3-82-001b
Air Oxidation Processes in
Synthetic Organic Chemical
 Manufacturing Industry —
 Background Information
for Promulgated Standards
         Emissions Standards Division
     U.S. ENVIRONMENTAL PROTECTION AGENCY
         Office of Air and Radiation
      Office of Air Quality Planning and Standards
      Research Triangle Park, North Carolina 27711
           June 1990

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                         ENVIRONMENTAL PROTECTION AGENCY

                              Background  Information
                     and  Final  Environmental  Impact Statement
                   for  Volatile Organic Compound  Emissions  from
                           Air Oxidation Processes in
                     Synthetic  Organic Chemical Manufacturing

                                  Prepared by:
 JapK R. Farmer      t
 Director, Emission Standards Division
 U. S. Environmental Protection Agency
 Research Triangle Park, North Carolina  27711

 1.    The promulgated standards of performance will  limit emissions of
       volatile organic compounds from mew,  modified,  and reconstructed air
       oxidation processes.   Section 111 of the Clean  Air Act (42 U  S  C
       rlrfl'™*Lmef    '  d1r?cts the Administrator to establish standards of
       performance for any category of new stationary  source of air pollution
       that  .  .  -causes  or contributes significantly to air pollution which
       may reasonably be anticipated to endanger public health or welfare."

 2.     Copies of this document  have been sent  to the following Federal
       Departments:   Labor,  Health  and Human Services,  Defensl  Transportation
       Arty* 1 f*l| 1 f IIV* A  F ntntnAvif* s\  T  i   *       jf*               «»^*y  '|viw^swii*uuiuil*

       Foundation;'state and'Territorial^ir Poir?JtioneprogramaAdministrators-
       Sf^if"!1  Adm1n\strators;  Local Air  Pollution  Control  Official;
       Office of  Management  and  Budget;  and other  interested  parties.

3.     For  additional  information contact:

      Mr. Doug Bell
      Standards  Development Branch  (MD-13)
      U. S. Environmental  Protection Agency
      Research Triangle Park, N. C.  27711
      Telephone:  (919) 541-5568

4.    Copies of this document may be obtained from:

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

      National  Technical Information Service
      5285 Port Royal Road
      Springfield, VA  22161

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

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                              TABLE OF CONTENTS

                                                                       PAGE

TITLE PAGE	: , . .     i
DISCLAIMER	    ii
LIST OF TABLES	    v1

1.0  SUMMARY	   1-1

     1.1  SUMMARY OF CHANGES SINCE PROPOSAL	   1-1
          1.1.1     Applicability of the Standards	   1-1
          1.1.2     Flare Operating Specifications 	   1-2
          1.1.3     Total Resource Effectiveness (TRE)
                    Coefficients 	   1-2
          1.1.4     Treatment of Compounds with Negligible
                    Photochemical Reactivity 	   1-3
          1.1.5     Monitoring Requirements	   1-3
          1.1.6     Net Heating Value Equation 	   1-4
          1.1.7     Maximum TRE Index Value	   1-4

     1.2  SUMMARY OF IMPACTS OF PROMULGATED ACTION 	   1-5
          1.2.1     Alternatives to Promulgated Action 	   1-5
          1.2.2     Environmental Impacts of Promulgated Action. . .   1-5
          1.2.3     Energy and Economic Impacts of Promulgated
                    Action	   1-5
          1.2.4     Other Considerations 	   1-6
                    1.2.4.1  Irreversible and Irretrievable
                              Commitment of Resources	   1-6
                    1.2.4.2  Environmental and Energy Impacts
                              of Delayed Standards 	   1-6

2.0  SUMMARY OF PUBLIC COMMENTS	   2-1

     2.1  AFFECTED FACILITY AND APPLICABILITY OF THE STANDARDS  ...   2-1
          2.1.1     Designation of Affected Facility  	   2-1
          2.1.2     Request to Limit Applicability of the
                    Standards	   2-10
          2.1.3     Request to Exclude Manufacture of Nitrogenous
                    Fertilizers from Ammoxidation Processes	   2-12

     2.2  SELECTION OF BEST DEMONSTRATED TECHNOLOGY	   2-12
          2.2.1     Consideration of Other Control Devices  	   2-12
          2.2.2     Application of Technologies with  Lower
                    Cost and Energy Requirements	   2-15
          2.2.3     Catalytic Oxidation	   2-16
                                     iii

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                   TABLE OF CONTENTS (CONTINUED)

                                                                  PAGE

2.3  MODIFICATION	   2-19
     2.3.1     Provision for Increased Emissions of
               Pollutants Other than VOC	   2-19

2.4  ECONOMIC IMPACT	   2-19
     2.4.1     Lowering Economic Feasibility Cutoff 	   2-19
     2.4.2     Plant Data Accuracy	   2-22

2.5  COST ESTIMATION	   2-23
     2.5.1     Change in Cost Procedure Base Year	   2-23
     2.5.2     Incinerator Cost Estimation Procedure	   2-24
     2.5.3     Discrepancies in Proposal BID Cost
               Information	   2-28
     2.5.4     Brine Disposal Costs 	   2-30

2.6  COST EFFECTIVENESS	   2-31
     2.6.1     Cost-Effectiveness Cutoff	   2-31
     2.6.2     Incremental Cost and Energy Impacts of
               Requiring 98 Percent Control 	   2-36

2.7  MONITORING AND MEASUREMENT METHODS 	   2-37
     2.7.1     Monitoring During Start-up, Shutdown, or
               Malfunction	   2-37
     2.7.2     Request to Waive Performance Tests and
               Monitoring Requirements	   2-38
     2.7.3     Alternative Methods of Demonstrating
               Compliance	   2-40
     2.7.4     Request to Define "Continuous" 	   2-40
     2.7.5     Request to Consider Alternative Measurement
               Methods	   2-41
     2.7.6     Verification of VOC Destruction Efficiency . .  .   2-41
     2.7.7     Catalytic Oxidation: Location of Sampling
               Site and Inclusion in Regulation	   2-42

2.8  EXEMPTIONS	   2-43
     2.8.1     Organic Pollutants with Negligible
               Ozone-Producing Capability  	   2-43

2.9  GENERAL	   2-45
     2.9.1     Documentation of Contacts with OMB	   2-45
                                IV

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                        TABLE OF CONTENTS (CONCLUDED)
                                                                       PAGE

APPENDIX A:  TRE EQUATION AND COEFFICIENT DEVELOPMENT FOR
               THERMAL INCINERATORS	   A-1
         A.I INTRODUCTION	   A-1
         A.2 INCINERATOR TRE INDEX EQUATION	   A-1
             A.2.1  Incinerator TRE Index Equation Development .  .  .   A-1
             A.2.2  Example Calculation of an Incinerator-based
                    TRE Index Value for a Facility	   A-4
APPENDIX B:  CAPITAL COST COEFFICIENTS
APPENDIX C:
FEDERAL REGISTER NOTICES OF ORGANIC COMPOUNDS
  DETERMINED TO HAVE NEGLIGIBLE PHOTOCHEMICAL
  REACTIVITY	
             INTRODUCTION.
             42 FR 35314  .
             42 FR 32042  .
             42 FR 48941  .
                                                          B-l
C-l

C-l
C-2
C-5
C-8

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                                LIST OF TABLES

            TITLE                                                      PAGE

2-1         List of Commenters on the Proposed Standards of
             Performance for Air Oxidation Processes in the
             Synthetic Organic Chemical Manufacturing Industry ....  2-2

A-l         Air Oxidation NSPS TRE Coefficients for Vent
             Streams Controlled by an Incinerator	A-3

A-2         Maximum Vent Stream Flowrates and Net Heating
             Value Characteristics for Each Design Category	A-5

B-l         Total Installed Capital Cost Equations as a
             Function of Offgas Flowrate 	  B-2
                                      vi

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                                 1.0 SUMMARY
     On October 21,  1983,  the Environmental  Protection Agency (EPA) proposed
standards of performance for air oxidation processes in the synthetic organic
chemical manufacturing industry (SOCMI) (48 FR 48931) under the authority of
Section 111 of the Clean Air Act (CAA).  Public comments were requested on
the proposal in the Federal  Register.  There were 11 commenters, most of whom
consisted of industry representatives.  Comments were also received from a
vendor of equipment used to control emissions from air oxidation processes,
and from a representative of an environmental group.  On May 16, 1985, EPA
reopened the period for receiving written comments on the proposed standards
(50 FR 20446) to allow public comment on the results of EPA's reanalysis of
the costing procedures, the total resource effectiveness (TRE) equation and
coefficients, and the designation of affected facility.  The reanalysis
resulted from public comments on the proposed standards and the acquisition
of new information collected since proposal.  The comments that were sub-
mitted, along with responses to these comments, are summarized in this
document.  The comments and subsequent responses serve as the basis for the
revisions made to the regulation between proposal and promulgation.

1.1  SUMMARY OF CHANGES SINCE PROPOSAL
     Several changes and clarifications were made in the regulation as a
result of the review of public comments.  These changes and clarifications
were made in the following areas: (a) applicability of the standards,
(b) flare operating specifications,  (c) TRE coefficients, (d) treatment of
compounds with negligible photochemical reactivity, (e) monitoring require-
ments, (f) net heating value equation, (g) maximum TRE index value, and
(h-) miscellaneous changes.

1.1.1  Applicability of the Standards
     In order to clarify the applicability of the standards, a list of
chemicals has been added to the regulation.  This list is contained in
Section 60.617, Chemicals Affected by Subpart III.  The list consists of the
36 chemicals which were identified in the background information document
                                     1-1

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(BID) as being entirely or partially produced by air oxidation processes.  To
accommodate this change, Section 60.610(a)  of the regulation has been amended
to read as follows:  "The provisions of this subpart apply to each affected
facility...that produces any of the chemicals listed in Section 60.617	"

1.1.2  Flare Operating Specifications
     Operating specifications for flares used to comply with requirements in
new source performance standards (NSPS) have been added to Section 60.18 of
the General Provisions (51 FR 2701, January 21, 1986) since proposal of the
air oxidation SOCMI NSPS.  Therefore, the regulation has been revised to refer
all owners or operators of affected facilities which use flares to comply with
this NSPS to the requirements in that section.

1.1.3  TRE Coefficients
     Table 1 of the regulation presents the coefficients associated with the
TRE index equation.  Some of the coefficients in this table were corrected to
predict more accurately the TRE indexes (and associated cost-effectiveness
values) of facilities.  The modifications to the coefficients in Table 1
resulted from changes in the costing procedures on which these coefficients
are based.  The changes in costing procedures and TRE coefficients are
discussed in the Agency's notice on reopening the public comment period for
the proposed air oxidation standards (50 FR 20446).
     Several modifications were also made in the format of Table 1 to provide
clarity to owners or operators of air oxidation facilities.  These
modifications included:  (a) the designation of Category Al and A2 streams was
changed from "chlorinated" to "halogenated"; (b) the designation for flow rate
was changed from "W" to Qs" so that the symbol  would match the symbol in the
EPA Reference Methods discussion;  (c) the term representing flow rate
intervals for selecting TRE coefficients was changed from "design standard
flow rate" to "vent stream flow rate" to indicate that actual operating flow
rate should be used in  selecting TRE coefficients;  (d) the first flow rate
interval was deleted because for all vent streams with flow rates below the
minimum incinerator size  (500 scfm)  [14.2 scm/min],  a flow rate of 500 scfm

                                      1-2

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  (14.2 son/rain)  is used for the purposes of calculating capital  and annual
  operating costs;  and (e)  the term representing flow rate for Category E
  streams  was changed from  "design  standard  flow rate" to "dilution flow rate -
  (Qs)(Hr)/3.6" to indicate  that dilution flow rate should be used in selection
  of TRE coefficients.

  1'1-4 Treatment  of Compounds  with Negligible  Photochemical  Reactivity
       Several  changes have  been made  in  the regulation  to  allow  facilities to
  subtract  compounds  with negligible photochemical reactivity  in  determining  a
  TRE index value.  The Agency believes that it  is appropriate to exclude those
  compounds in  the  regulation since they do not  contribute  appreciably to the
  formation of  ozone.
      To allow for subtraction  of compounds with negligible photochemical
 reactivity in determining a TRE index, the Agency has amended the definition
 of total  organic compounds (TOC's) in the regulation.  The definition of TOC
 in Section 60.611  has been amended to indicate that the definitin of "TOC"
 means  TOC less all compounds that  have been determined by the Administrator to
 possess negligible photochemical  reactivity.   This  definition is used only
 when applied to  Sections 60.614(d)(2)(1),  measuring molar composition;
 60.614(d)(5),  the  hourly emission  rate (E^);  60.614(e)(l) and (e)(2),  the
 TRE index calculation;  and  60.615(b)(4)  and  60.615(g)(4),  the calculation of
 absorber,  condenser, or carbon  adsorber  TOC  vent stream concentration.   For
 all  other quantifications of TOC under these standards,  VOC equals  TOC  less
 methane and  ethane as defined  in Section 60.614.  The Federal  Register
 citations  for  the  list  of negligibly  photochemically  reactive compounds  that
 may  be  subtracted  are presented in Appendix C and have  also been added  to the
 definition of  TOC  in Section 60.611 of the regulation.

 1'1-S  Monitoring  Requirement*

     The "continuous recording" requirements have been changed.  All
measurements such  as firebox temperature, absorber liquid specific gravity,
carbon  adsorber steam mass  flow rate and other methods for demonstrating
compliance with the standards are now required to be taken at least every

                                      1-3

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15 minutes.  There are several advantages to this change in monitoring
requirements:  (1) computer-assisted monitors are allowed, (2) the parameter
measurement frequencies required for monitoring and continuous recording are
consistent with the frequencies required for compliance testing, and (3) the
same equipment may be used for both monitoring and compliance testing.

1.1.6  Net Heating Value Equation
     To be sure that the net heating value is calculated on a wet basis, the
definition of symbol "C," in Section 60.614(c)(4) was amended to include "on a
wet basis."  The net heating value must be calculated on a wet basis because
the entire vent stream, including water vapor, would be combusted, and
therefore this is the heating value used in calculating a TRE value.
     The reference method for determining the concentration of carbon monoxide
in the vent stream was changed from the EPA Reference Method 10 to ASTM D1946-
82.  Section 60.614(d)(2)(ii) has been amended accordingly.

1.1.7  Maximum TRE Index Value
     Several changes were made in the regulation to provide for inclusion of a
maximum TRE index value.  The maximum TRE index value of 4.0 represents the
value above which monitoring and recordkeeping requirements would not be
imposed on a facility attempting to comply with the standards.  It is the
judgement of the Agency that facilities with TRE index values above the
maximum could not lower the TRE index value below the cutoff without making a
process change.  Thus, the Agency believes that the monitoring and
recordkeeping burden should not be imposed on such facilities.  However, if a
process change occurs, the facility should recalculate the TRE index value as
required in Section 60.614(e).  If the recalculated TRE index value is less
than or equal to 1.0, the owner or operator shall notify the Administrator
within 1 week of the recalculation and shall conduct a performance test
according to the methods and procedures required by Section 60.614 to
determine compliance with Section 60.612(a).  If the recalculated TRE index
value is less than or equal to 4.0, but greater than 1.0, the owner or
operator shall conduct a performance test according to the methods and

                                      1-4

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procedures required by Section 60.614 and shall  comply with Sections 60.613,
60.614, and 60.615.  Sections 60.610, 60.614,  and 60.615 of the regulation
have been amended to incorporate the requirements associated with the maximum
TRE index value.  If the TRE index value remains above 4.0, the owner or
operator need only keep a record of the recalculation.

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 proposal
BID.  These regulatory alternatives reflect the different estimated
percentages of facilities required to reduce emissions by 98 weight-percent
or to 20 parts per million by volume (ppmv) under a particular cost-
effectiveness cutoff.  These regulatory alternatives were used in selection
of the best demonstrated technology (BDT), considering the estimated cost
impacts,, nonair quality health impacts, environmental impacts, and economic
impacts associated with each alternative.  These alternatives have not been
changed.

1.2.2  Environmental Impacts of Promulgated Action
     The changes in the regulation described above will have a minor effect
on the estimated air quality impacts attributed to the standards as originally
proposed.  The new estimated air quality impacts of the standards are pre-
sented in the Agency's notice reopening the public comment period for the
proposed air oxidation standards (50 FR 20446).  The changes in the regulation
will have a negligible impact on the water quality and solid waste impacts
attributed to the standards as originally proposed.  These impacts are
described in Chapter 7 of the proposal BID.  That analysis of environmental
impacts along with the new air quality impacts presented at 50 FR 20446 now
constitute the final Environmental Impact Statement for the promulgated
standards.

1.2.3  Energy and Economic Impacts of Promulgated Action
     Section 7.4 of the proposal BID describes the energy  impacts and
Chapter 9 describes the economic impacts of the proposed standards.  The
                                     1-5

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changes In the regulation described above will  have a negligible effect on
these Impacts.

1.2.4  Other Considerations
     1.2.4.1  Irreversible and Irretrievable Commitment of Resources.
Chapter 7 of the proposal BID concludes that other than fuels required for
the operation of volatile organic compounds (VOC's) control  equipment, there
is no apparent irreversible or irretrievable commitment of resources
associated with the standards.  The use of the  TRE concept encourages  the use
of recovery techniques or process changes to recover pollutants as products.
The control of VOC emissions using recovery techniques or process changes
might be an alternative to adding combustion controls for some air oxidation
facilities.  This would result in the conservation of both chemicals and
fuels.  The changes in the regulation described above will have no impact on
the commitment of resources.

     1.2.4.2  Environmental and Energy Impacts  of Delayed Standards.
Table 1-1 in the proposal BID summarizes the estimated environmental and
energy impacts associated with promulgation of  the standards.  If the
standards were delayed, adverse impacts on air  quality could result.  A delay
in promulgation would mean that affected facilities would be controlled to
the level specified in the appropriate State implementation plan (SIP).
Emission levels would consequently be higher than would be the case were the
standards in effect.
                                     1-6

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                         2.0  SUMMARY OF PUBLIC COMMENTS
        /
       A total  of 12 letters commenting  on  the  proposed  standards  were
  received.   In addition,  one speaker appeared  at  the  public  hearing to comment
  on  the proposed standards.    The  transcript from the public hearing,  comments
  on  the proposed standards  made  at the  public  hearing,  and the  12  letters
  commenting  on the  proposed  standards have been recorded and placed in the
  docket.  The  list  of commenters,  their affiliation,  and-the EPA docket  item
  number for  each  of the comments are shown in  Table 2-1.  The docket  reference
  is  indicated  in  parentheses  in each comment.  Unless otherwise noted, all
  docket references  are part of Docket Number A-81-22, Category  IV.  The
  comments have been organized into the following nine categories:

      2.1    Affected Facility and Applicability of the Standards
      2.2    Selection of BDT
      2.3    Modification
      2.4    Economic Impact
      2.5    Cost Estimation
      2.6    Cost Effectiveness
      2.7    Monitoring and Measurement Methods
      2.8    Exemptions
      2.9    General

2.1   AFFECTED  FACILITY AND APPLICABILITY OF THE STANDARDS

      2.1.1 COMMENT:  One commenter  (D-6, D-6a) stated that the definition of
affected facility contained in the proposed regulation does  not conform with
the requirements of the CAA insofar as it allows two or more air oxidation
reactors which are joined to a common product recovery system to be inter-
preted as  one affected facility.   As an  example, the commenter pointed out
that if an existing facility consists of a  single  reactor,  any changes in
                                     2-1

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                                   TABLE  2-1

        List  of Commenters  on  the  Proposed  Standards  of Performance  for
           Air Oxidation Processes in  the Synthetic Organic Chemical
                            Manufacturing Industry

                           Docket  Number  A-81-22,  IV

                                Public Hearing

Commenter                                                     Docket Reference

Mr. A. W. Byer                                                         F-l
Process Engineering Consultant
Union Carbide Corporation
Post Office Box 8361
South Charleston, West Virginia  25303

                                    Letters

Mr. H. Neal Troy                        .                              D-l
Manager, Environmental Control
Owens-Illinois, Incorporated
One SeaGate
Toledo, Ohio  43666

Mr. A. H. Nickolaus                                                    D-2
Chairman, CTG Subcommittee
Air Conservation Committee
Texas Chemical Council
1000 Brazos, Suite 200
Austin, Texas  78701

Mr. D. C. Macauley                                                     D-3
Environmental Affairs Manager
Union Carbide Corporation
Post Office Box 8361
South Charleston, West Virginia  25303

Mr. William T. McShea,                                                 D-4
Manager, TORVEX Environmental Products
Engelhard Industries Division
2555 U.S. Route 22
Union, New Jersey  07083

Mr. Mark Urbassik                                                      D-5
Manager, Environmental Regulatory Programs
Koppers Company, Inc.
Pittsburgh, Pennsylvania   15219


                                      2-2

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Commenter                                                     Docket Reference

Dr. David D. Doniger                                                  D-6
Senior Staff Attorney
Natural Resources Defense Council, Inc.
1725 I Street, N.W., Suite 600
Washington, D.C.  20006

Geraldine V. Cox, Ph.D.                                               D-7
Vice President
Technical Director
Chemical Manufacturers Association
2501 M Street, N.W.
Washington, D.C.  20037

Mr. Gary D. Myers                                                     D-8
President
The Fertilizer Institute
1015 18th Street, N.W.
Washington, D.C.  20036

Mr. A. G. Smith                                                       D-9
Manager, Environmental Affairs
Shell Chemical Company
One Shell Plaza
Post Office Box 2463
Houston, Texas  77001

Mr. J. D. Reed                                                        D-10
General Manager
Environmental Affairs and Safety
Standard Oil Company  (Indiana)
200 East Randolph Drive
Chicago, Illinois  60601

Mr. Keith M. Bentley                                                .  D-ll
Senior Environmental  Engineer
Georgia-Pacific Corporation
133 Peachtree Street, N.E.
Post Office Box 105605
Atlanta, Georgia  30348
                                      2-3

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Commenter                                                     Docket Reference

Mr. R. F. Kelley                                                      D-12
Assistant Corporate Director
Environmental Affairs
Union Carbide Corporation
Old Ridgebury Road
Danbury, Connecticut  06817

Mr. D. C. Macauley                                                    D-13
Environmental Affairs Manager
Union Carbide Corporation
Post Office Box 8361
South Charleston, West Virginia  25303

Geraldine V. Cox, Ph.D.                                               D-14
Vice President
Technical Director
Chemical Manufacturers Association
2501 M Street, N.W.
Washington, D.C.  20037
                                      2-4

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  that reactor during a 2-year period which result in cumulative costs of over
  50 percent of the capital  cost of a new reactor would make that reactor an
  affected facility.   However,  if two or more reactors are joined in an
  existing facility,  similar changes to one reactor may not make that facility
  subject  to the standards because the capital  costs are not likely to exceed
  50 percent of the capital  cost of the entire  facility (i.e.,  single reactor
  plus combined reactors).   Thus,  allowing  two  or more reactors to  be joined in
  the same affected facility would cause more emissions from air oxidation
  reactors to  go uncontrolled than would be  the case were  each  reactor treated
  as  a separate affected facility.
       According  to the commenter,  this  broad definition of  affected  facility
  in  effect  legislates a mechanism by which  certain  facilities  may  avoid the
  standards.  The commenter  stated  that  the  broad definition  is  not consistent
 with the holding  in ASARCO  v. EPA, 578 F.2d 319  (D.C. Cir.  1978), which held
 that the Agency could not define  affected  facility in a way which would allow
 major units of production to go unregulated under the new source performance
 standards  (NSPS) without offering justification for the differential
 treatment of identical  sources.   In this instance, the commenter concluded,
 the Agency has offered no justification for holding reactors to different
 standards depending on  whether they are or are not joined to a common product
 recovery  system.
      The  commenter offered  several suggestions for rectifying  the  definition.
 First,  the commenter recommended  that all  reactors be defined  as affected
 facilities.  Alternatively,  the commenter  suggested that  for cases where
 several reactors are joined to  a  common product  recovery  device the  NSPS
 require a partial  reduction  in  the total VOC emissions  from the group of
 reactors.   The partial reduction  should be  equivalent  to  the reduction that
 would  be  required  in  the emissions  from the single  new  reactor were  it the
 only  one  connected to the product  recovery  system.  A third  suggestion
 recommended by the commenter is that the Agency lengthen the period of time
 over which capital  investments will be  accumulated in order  to determine
whether a reconstruction has occurred.
                                     2-5

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     RESPONSE:  As the commenter suggests,  EPA's definition of the "affected
facility" in NSPS must be consistent with the definition of the term
"stationary source" in Section 111 of the CAA, as interpreted by the U. S.
Court of Appeals of the D.C. Circuit in ASARCO v. EPA.  578 F.2d 319 (1978).
As the commenter notes, the Court in ASARCO discussed the scope of EPA's
discretion in choosing the affected facility.  The Court stated:
     The EPA's definition of a "facility",  which this court accepts, is "any
     apparatus to which a standard of performance is specifically
     applicable."  [Citation omitted.]  This definition is clearly designed
     to designate as "facilities" those units of equipment -- be they
     individual machines, combinations of machines, or even entire plants --
     that the Agency finds to be appropriate units for separate emission
     standards.  A cursory review of EPA's regulations indicates that the
     units designated as "facilities" under this definition are usually
     larger than individual machines or single pieces of equipment, and are
     sometimes whole plants.  [Citation omitted.]  In designating what will
    'constitute a facility in each particular industrial context, EPA is
     guided by a reasoned application of the terms of the statute it is
     charged to enforce, not by an abstract "dictionary" definition.  This
     court would not remove this appropriate exercise of the Agency's
     discretion.  [Citations omitted.]  578 F.2d at 324 n. 17.
    Consistent with this statement, EPA has selected the affected facility in
the air oxidation standards by looking at the terms and purposes of Section
111, as well as the characteristics of air oxidation plants.  As EPA stated
at proposal, the main purpose of Section 111 is to minimize emissions by
requiring the application of BDT at all new, modified,  and reconstructed
sources (considering cost, nonair quality health and environmental effects,
and energy impacts).  The EPA believes that in most cases a narrow affected
facility designation will best further this purpose, because in most cases a
narrow designation ensures that all new emission units will be brought under
the coverage of the standards.  If, for example, an entire plant is
designated as the affected facility, no part of the plant would be covered by
the standards unless the replacement caused the plant as a whole to be
"modified" or "reconstructed."  If each piece of equipment is designated as a
separate affected facility, then as each piece is replaced, the replacement
piece would be a new source subject to the standards.  For this reason, EPA
uses a presumption that the narrow designation is appropriate.
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     The EPA treats the narrow designation only as a presumption, however,
because in some cases a broader affected facility may be more consistent with
the purposes of Section 111.  For example, the Agency might choose a broader
designation if it concluded that either: (a) it would result in greater
emissions reduction than would a narrow designation; or (b) the other
relevant statutory factors (technical feasibility, economic, cost, energy,
and nonair quality health and environmental impacts) point to a broader
designation.
     The EPA analyzed several alternative affected facility definitions for
the air oxidation standards, including: (1) each individual reactor with its
recovery system, (2) the group of reactors whose streams are ducted together
through a single recovery system, and (3) the entire plant.  Using the
presumption mentioned above, EPA defined as a single affected facility each
reactor whose stream is sent to its own recovery system.  The EPA concluded,
however, that when reactor streams are joined and sent through a single
recovery system the group reactors and their recovery system, rather than
each reactor, should be a single affected facility.
     The EPA estimates a greater reduction in national VOC emissions using
the broader designation of affected facility.  Greater reduction in emissions
will occur with the broader designation because for facilities where the TRE
index  is less than 1.0, emissions from existing air oxidation reactors will
also be controlled when new reactors are combined with existing reactors
sharing a common recovery system.  Under a narrow designation, when a new
reactor is combined with existing reactors, the new reactor is treated
separately.  Thus, only emissions from the new reactor could potentially be
controlled.
     The commenter did not comment on this reasoning.  Instead the commenter
contended that when more than one reactor  is vented to the same recovery
device EPA's designation will permit reactor replacements to avoid coverage
under  the standards and will therefore result in less emission reduction than
would  occur if the comnenter's affected facility designation were used.  The
EPA disagrees with the commenter's analysis and conclusion.  The replacement
of air oxidation reactors or pieces of recovery equipment  is rare within the
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industry.  This is because reactors are expensive pieces of equipment which
are designed to last a long time.  Moreover, the Agency has concluded that
those few replacements which do occur often result from process changes
(e.g., from chlorination to hydrochlorination) or catastrophic events that
would probably require replacement of most of the group of reactors joined to
a single recovery system.  These changes would likely amount to a "recon-
struction" of the facility as it is defined in these standards.  Thus, in the
small percentage of cases where reactor replacements occur, the facility
would most likely fall under the coverage of the standards.
     Furthermore, as EPA stated at proposal, the other types of reactor
changes that source owners would most likely consider are substantial changes
in catalysts, reactor conditions, or product separation purification equip-
ment.  The cost of these changes is so great, however, that most owners would
choose to build new groups of reactors rather than radically modify
individual existing reactors.  Thus, few air oxidation reactors would undergo
process changes that would subject them to the standards under either the
commenter's or EPA's designation.  Moreover, under EPA's designation, in the
event an owner added a reactor to an existing group of reactors ducted to the
same recovery system, it is unlikely the facility could avoid being con-
sidered a modification by offsetting the new reactor emissions somewhere else
within the reactor group.  This is because it would likely be technologically
infeasible to reduce emissions sufficiently or at all from the other
reactors.  Although some VOC reductions could occur through upgrading
recovery equipment, it is unlikely that this reduction would result in a full
offset of the new reactor emissions because the increased load on the
recovery device (i.e., increased flow and VOC) would make the needed increase
in VOC removal efficiency difficult to achieve.  Thus, the likely result is
that addition of a reactor to a group of joined reactors would bring the
entire set under the coverage of the standards as a modified facility.
     In short, the broad evasion of the modification and reconstruction
provisions that might generally occur under broad affected facility
designations would not occur under EPA's designation for the air oxidation
standards.  As discussed above, under EPA's designation, the inability of
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  owners or operators  to offset  emissions  from new reactors  added to a set of
  existing  reactors  would likely cause  the entire  set  of new and  existing
  reactors  to  come under the  standards  as  a modified facility.  This results  in
  a  greater emission reduction potential than  would be the case for  these
  reactors  under  a narrow designation.  For these  reasons, EPA disagrees with
  the commenter's premise that the affected facility designation  in  these
  standards  would result  in foregone emission  reductions  and would therefore  be
  inconsistent with  Section 111.  Rather,  EPA's selection of the  affected
  facility represents a reasoned application of Section  111, consistent with
  ASARCO, because it couples consideration of  both  the need to secure the
  greatest emissions reductions from new and modified emission units with the
  technological realities of the air oxidation process.
      A second reason for selecting the broader designation of affected
 facility is that it facilitates implementation of the standards.  When
 several reactors feed process vent streams into a common recovery system, the
 characteristics  of the emissions vented  into the atmosphere from the recovery
 system are determined by both the process vent streams  from each of the
 reactors and  the efficiency  of  the recovery  system.   Determining accurately
 the contribution of each individual  reactor  to these  emissions  (i.e.,  each
 reactor's  TRE index value) can  be  complex and,  therefore, costly.   It
 requires a mass  balance calculation  using three  sampling sites:  two which are
 located upstream and  downstream of the recovery  system  and  one located  just
 downstream of the reactor.
     Under  the broader  designation EPA is  promulgating,  however,  only one
 sampling site located after the last recovery device  is  needed to yield an
 accurate determination of the facility's TRE  index value.  No estimation of
 the recovery device efficiency on individual   reactors is required because the
 standards cover the entire vent stream.  Therefore, there is no  need to
 determine which portion of the final  vent stream from a group of reactors is
 attributable to new, modified, and reconstructed reactors and which portion
 is attributable to reactors that have not been changed or added.   This
results in a decrease in both the cost  and complexity  of performance testing
because fewer  sampling sites  and_a simpler analysis are  needed.
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      Finally, the Supreme Court recently upheld EPA's similar interpretation
of the same term, "stationary source", in a similar context.  Chevron,
U. S. A.. Inc. v. NRDC. 467 U. S. 837, 104 S.Ct. 2778 (1984).  In that case,
EPA had defined the term as an entire plant for the purpose of implementing
the Section 173 new source permit requirements.  The Court deferred to the
Agency's interpretation because Congress had not indicated how it would define
the term and EPA's construction was rational in light of the purposes of the
new source review program.
      In reaching the first conclusion, the Court noted that Congress has
defined "stationary source" in Section 111 as "any building, structure,
facility, or installation" that emits air pollution.  The Court found this
definition unclear, however, and held:

            To the extent any Congressional "intent" can be
            discerned from tnis language, it would appear that the
            listing of overlapping, illustrative terms, was
            intended to enlarge, rather than confine, the scope of
            the Agency's power to regulate particular sources in
            order to effectuate the policies of the Act.

      Id. at 2791.  Thus, Chevron supports the view that Congress left EPA
significant discretion to interpret the definition of "stationary source" for
purposes of implementing Section 111, so long as the Agency's interpretation
is reasonable in light of the statute's purposes.  The EPA has exercised this
discretion by defining the "affected facility" in the air oxidation NSPS as a
collection of equipment that is smaller than an entire plant but larger than
each individual reactor.  As indicated above, that definition reflects
consideration of the complexity of reactor-specific emission measurement, as
well as the degree of emission reduction that would result under the available
alternative definitions -- two factors centrally relevant to the purposes of
Section 111.   In light of Chevron. EPA feels that this represents a
reasonable exercise of its discretion in interpreting the statute.

      2.1.2 COMMENT:  Three commenters (D-7, D-10, and D-ll) requested
clarification on the applicability of the standards.  One commenter (D-ll)
stated that the definition of affected facility contained in the proposed
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  regulation does not specifically limit the applicability of the standards to
  air oxidation processes in the SOCMI.   Consequently,  the proposed standards
  could be interpreted as also applying  to air oxidation reactors in other
  industries such as asphalt roofing and kraft pulp mills.   Three commenters
  (D-7,  D-10,  and D-11)  recommended that the applicability provisions of the
  proposed regulation be amended to specify that  the standards  are applicable
  only to  air  oxidation  processes  which  are used  in  the  manufacture of certain
  listed chemicals.   Two of  the  commenters  (D-7 and  D-10)  specifically
  recommended  that this  list  include  those  which were included  in  the  standards
  for  fugitive emissions  from  the  SOCMI  at  40  CFR 60.489.  The  third commenter
  (D-11) recommended  that the  36 chemicals which were evaluated in  the BID for
  air  oxidation processes be incorporated into the proposed standards.

      RESPOND:  In order to clarify the applicability of the standards
 several changes have been made in the regulation.   The Agency has amended
 Section 60.610(a) of the regulation to  read as follows:  "The provisions of
 this subpart apply to each  affected facility...that produces any of the
 chemicals listed in Section 60.617...."  A list  of affected chemicals has also
 been added to Section 60.617.  The Agency believes that this list will  clarify
 the applicability of the standards.   The list consists  of the  36 chemicals
 which were identified in the  BID  as  being  entirely or partially  produced  ny
 air oxidation processes.  The list included in the  standards for  fugitive
 emissions  from SOCMI  facilities includes many chemicals which  are not produced
 by  air  oxidation  and  thus is  not  appropriate  for the air oxidation  standards
      To the Agency's  knowledge, none of the listed  chemicals are  produced at
 asphalt roofing plants  and kraft  pulp mills using air oxidation processes
Thus, air oxidation processes at  asphalt roofing and kraft pulp mills would
not be covered by these standards.  If any of the listed chemicals were
produced as intermediates or final products at asphalt roofing plants or kraft
pulp mills, the facility producing the listed chemical  would be covered by the
standards.
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     2.1.3 COMMENT:  One commenter (D-8) stated that it should be made clear
that the provisions which specify that the standards apply to ammoxidation
processes refer to the production of synthetic organic chemicals such as
acrylonitrile, and not to processes for the manufacture of nitrogenous
fertilizers.
     RESPONSE;  As stated in the response to comments 2.1.2, applicability of
the standards is limited specifically to air oxidation processes (including
ammoxidation and oxychlorination) within the SOCMI.  Only those chemicals
listed in Section 60.617 are subject to the proposed standards.  This list
does not include any nitrogenous fertilizers.  However, if any of the listed
chemicals were produced as intermediates or final  products at a fertilizer
plant using an air oxidation process, the facility at that plant would be
covered by the standards.

2.2  SELECTION OF BDT

     2.2.1 COMMENT;  Three commenters (D-2, D-4, and D-7) indicated that the
selection of BDT was too restrictive in not allowing the use of other control
devices.  One commenter (D-2) stated that catalytic oxidizers, boilers,
process heaters, and flares should be allowed as alternate combustion tech-
nologies.  Another commenter (D-7) indicated that all of these technologies
have VOC destruction efficiencies comparable to those of thermal incinera-
tors.  This commenter indicated that catalytic oxidation and flaring could be
more cost effective than thermal incineration for an individual plant.
Furthermore, the commenter stated that the regulation should allow the use of
other available technologies (e.g., membranes, wet air oxidation) that
achieve control efficiencies which are less than the 98 percent combustion
requirement, but which may be greater than those needed to meet the TRE
cutoff of 1.0.  A third commenter (D-4) indicated that catalytic oxidation is
widely used within the industry and can be an attractive alternative to
thermal incineration.
     Three commenters (D-2, D-4, and D-7) stated that in analyzing regulatory
alternatives inadequate consideration was given to control technologies other
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  than thermal  incineration.   The commenters believe that the combustion
  devices listed above should also have been analyzed.

       RESPONSE:   The  regulation  does  not  prohibit  the  use of any control
  device  that reduces  VOC  emissions  by 98  weight-percent  or to 20 ppmv  (which-
  ever is less  stringent).  These emissions  reduction requirements represent
  the  capabilities of  thermal  oxidation  which the Agency  believes is  BDT.
  Based upon available data,  the  Agency  believes that those  combustion  devices
  mentioned by  the commenters  are capable  of achieving  98  percent VOC
  destruction efficiency in cases  where  they are applicable.   Therefore, the
  standards do  allow the use of alternative control techniques, such as
  boilers, process heaters, flares, and  catalytic oxidizers, as long as the
  owner or operator of a facility using  one of these devices can demonstrate
  that the emission reduction requirements and/or limits are achieved.  The
  control  techniques (i.e., membranes,  wet air oxidation)  identified by the
 commenter that do not achieve 98 weight-percent VOC reduction or 20 ppmv
 outlet concentration  are not allowed.  If these techniques were found to be
 capable  of achieving  these emission reduction  requirements they would be
 allowed.  Under such  circumstances,  the owner  or  operator of an affected
 facility using these  devices would  be required to  demonstrate compliance as
 indicated in Section  60.613(e).   The  owner  or  operator would also have to
 provide  information describing the  operation of the  control  device and the
 process  parameter(s)  which would indicate proper operation and maintenance of
 the control device.
      Several commenters were  concerned  that the Agency did  not adequately
 consider alternative  control  techniques in analyzing regulatory  alternatives.
 In order to analyze the impacts  of this regulation upon all segments of the
 industry, EPA  first attempted to  identify a technology or technologies that
would be  available to all potentially affected SOCMI air oxidation
facilities.  Thermal  oxidation was the  technology that best met  this
qualification for the industry as a whole.  Consequently, EPA  focused on
thermal oxidation for the purposes of the impacts  analysis.  Thermal
oxidation is an expensive VOC control  technique relative  to other available
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control techniques.   The use of thermal  oxidation in the TRE equation
prevents an underestimation of the costs that may be incurred by facilities
since no facility will  use a more expensive device and,  in fact, some
facilities will  use  less expensive devices such as flares, boilers,  process
heaters, and catalytic oxidizers.  However, for these other control  tech-
niques EPA was unable to identify any subcategory of air oxidation vent
streams where these  devices would always be applicable.
     The other available VOC control  techniques (i.e., catalytic oxidizers,
boilers, process heaters, and flares) were examined, but were not included in
the impacts analysis for various reasons.  Although catalytic oxidizers are
capable of achieving 98 percent destruction efficiency,  some air oxidation
vent streams may have characteristics which would limit the applicability of
catalytic oxidizers.  For example, vent streams with high heating values or
vent streams with compounds that may deactivate the catalyst may not be
suitable for applying catalytic oxidizers.  Catalysts can be deactivated by
compounds sometimes  present in the waste stream, such as sulfur, bismuth,
phosphorus, arsenic, antimony, mercury,  lead, zinc, or tin.  Deactivation of
the catalyst may also occur at high temperatures.  Because of these
susceptibilities to  individual waste stream characteristics, catalytic
oxidation has not been demonstrated to be universally applicable for VOC
emissions reduction  from all air oxidation processes.  The VOC destruction
efficiencies may vary among processes and among plants.   Although catalytic
oxidation was not included in the impacts analysis, in many cases this device
may be able to meet  the 98 percent VOC reduction requirement as stated above.
However, the Agency is unable with available information to identify sub-
categories of air oxidation processes for which these technologies would
always apply.
     Other combustion devices, such as boilers, process heaters, and flares
were also examined and found not to be universally applicable.  However, in
many cases, these devices can achieve 98 percent VOC reduction under various
operating conditions and thus are permitted as control devices subject to  a
compliance demonstration (except for boilers greater than 44 MW
(150 million Btu/hr)), which are .exempted from the compliance demonstration
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requirement).   The Agency,  however,  cannot identify those specific facilities
for which these technologies can always be used,  and therefore, they cannot
form the basis for analysis of industry-wide impacts.  Flares were not
considered before proposal  because they are generally not used to control air
oxidation emissions in the SOCMI.  Low heat content offgas streams such as
those found in air oxidation processes are typically not combusted in flares
before a substantial amount of supplemental fuel  would be required to increase
the offgas heat content.  However, the Agency does not intend to exclude the
use of flares.  To facilitate their use, th« Agency has added operating
specifications, monitoring requirements, test methods, and a TRE equation to
the regulation for flares to provide guidance to those owners or operators of
an affected facility planning to comply with the standards by using a flare.

      2.2.2 COMMENT:  One commenter (D-6, D-6a) recommended that technologies
which involve lower costs and energy requirements than thermal incineration be
evaluated for application to reactors for which thermal incineration has been
determined to have too high a cost per ton of VOC destroyed.  Specifically,
the commenter pointed to product recovery devices, such as carbon adsorption,
or other devices  such as catalytic oxidation as technologies which should be
examined further  by the Agency  for application to sources which are currently
exempted from the thermal  incineration requirement of the proposed regulation.

      RESPONSE:   Catalytic  oxidizers and  product/by-product recovery devices
(e.g.,  adsorbers, absorbers, and condensers) were examined but were not
considered as alternative  BDT for facilities with a  TRE  index  above 1.0.  The
reason  they were  not  considered is that the Agency was unable  to  identify
subcategories for which these devices would always  apply.  Section  11 of the
CAA requires  the  Agency to  demonstrate  that a  technology  is  applicable  in all
representative  conditions.   In  the National Lime Association v. EPA. 627 F.2d
416  (D.  C. Cir,  1980),  the  Court  held  that  the Agency must account  for  the
factors that  may  contribute to  the efficiency  of the emission  control  system
or to the  amount  of emissions that would  be discharged from  the
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emission control system.  The Agency recognizes that in  some cases it may be
appropriate to develop subcategories for which different types or levels of
control would apply.  However, in the case of the air oxidation NSPS this is
not feasible.
     The performance of catalytic oxidizers is sensitive to many air
oxidation process vent  stream characteristics such as those described in the
response to comment 2.2.1.  The performance of product/by-product recovery
devices may be  greatly  affected by the vent stream flow rate, water content,
temperature,  VOC concentration, and VOC properties such as  solubility,
molecular weight, and liquid/vapor equilibrium.  Since  these  characteristics
vary widely within  the  industry,  it  is not possible  with available  informa-
tion and resources  to  identify  subcategories  of  air  oxidation processes for
which  these  devices would always  be  applicable and  to specify control
efficiencies under  an  industry-wide standard  approach.   Even with greater
 resources,  this approach would  be infeasible  because it would require a
 stream-by-stream characterization,  ultimately resulting in the need for a
 separate standard for each individual air oxidation process used to produce a
 listed chemical.  The number of standards required to regulate the same
 number of sources would  increase significantly.  The Agency feels that such
 an approach  to regulating the air oxidation industry would be
 administratively infeasible  and therefore environmentally counterproductive.
 In any event,  as the commenter recognizes, proceeding  now with this generic
 regulation based on thermal  incineration at  least represents  an  important
 first step  in  regulating air oxidation emissions and does  not preclude later
 regulation  of  subcategories of air  oxidation facilities should  that  become
 feasible    The EPA believes it has  the  authority to take  this step-by-step
  approach  under Section 111. See,  e^,  fironp Against  Smog and  Pollution
  v.-EPA,  665 F.2d 1284 (D. C. Cir.  1981).

       2 2 3 COMMENT:   Two commenters (D-3 and D-4)  implied that the emission
  reduction Squired in the regulation should be lowered to make provision for
  catalytic oxidation as  a resource-effective control method.  One commenter
  (D-3) indicated that  catalytic oxidation could achieve a VOC destruction
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efficiency close to that of thermal  incineration at a lower cost effective-
ness.  However, the commenter indicated that to achieve 98 percent emissions
reduction his firm would have to install a thermal  incinerator after the
catalytic oxidizer.
     Another commenter (D-4) indicated that although catalytic oxidation can
be designed for VOC destruction efficiencies higher than 99.9 percent (i.e.,
comparable to efficiencies for thermal incineration), economic factors
dictate whether these levels are practical.  The commenter added that the
98 percent destruction efficiencies associated with the proposed standards
would possibly require the use of uneconomically large catalyst volumes in
catalytic incinerators or the use of thermal incinerators.  The commenter
pointed out that neither of these options may result in a measurable
improvement in the environment over the case of catalytic oxidation at an
efficiency slightly lower than 98 percent.  Furthermore, the use of thermal
incineration instead of catalytic oxidation may possibly entail the following
detrimental effects: (a) higher energy  usage by the  affected plants,  (b) an
increase  in NO  emissions from the affected plants using thermal
incineration,  and  (c) a decrease in the competitive  position of domestic
chemical  producers with respect to foreign competition.

      RESPONSE:  The Agency  has decided  to make  no  changes  in the emission
reduction requirements of the standards.  The  standards require facilities  to
achieve  an emission reduction that reflects the capabilities of BDT,  which
for  certain  facilities  is reduction of  VOC emissions by 98 weight-percent  or
to 20 ppmv through  incineration.  The  standards do not prohibit the
application  of any  devices,  including  catalytic oxidizers, which are  used  to
comply with  the emission reduction requirements and/or emission limits.  The
Agency believes,  based  upon available  data, that catalytic oxidizers  are
capable  of achieving 98  percent destruction efficiency  in  all  cases where
they are applicable.  Since both types  of units can  meet  the 98 weight-
percent  reduction  or 20  ppmv limit, the owner  or operator  would have  the
flexibility  to choose the device which  he believes is  best for the facility
in terms of  cost  or other technical considerations.
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     Catalytic oxidizers do not,  however,  necessarily have the advantages
over thermal incinerators named by the commenters.   Because of the potential
for greater heat recovery associated with  recuperative heat exchangers used
in conjunction with thermal incinerators,  thermal  incinerators may in many
cases be less expensive and use less energy than catalytic oxidation units.
This has to be examined on a case-by-case  basis by owners or operators with
facilities which can use catalytic oxidation.   For these reasons,  catalytic
oxidation does not necessarily have any advantage over thermal incineration
in terms of price impacts or competitive position of domestic producers
relative to foreign competition,  as suggested by the commenters.   The
potential impacts of domestic price increases associated with thermal
incineration were investigated and are not considered to be large enough to
significantly affect the competitive position of domestic producers relative
to foreign competition.  Using conservative (high) control cost estimates,
chemical price increases are estimated to  range from 0 to about 3 percent.
Further, the potential for increased NO  emissions associated with thermal
                                       ^
incineration was also examined, but the rate of NO  formation is expected to
                                                  A
be low due to relatively low combustion temperatures and relatively short
residence times.
     One commenter stated that to achieve 98 percent emissions reduction with
a catalytic oxidizer his firm would have to install a thermal incinerator
after the catalytic oxidizer.  In order to evaluate this statement, the
Agency requested information to determine the cost effectiveness of achieving
98 percent destruction efficiency with  catalytic oxidation.  However, the
commenter indicated that no data were available.  Also, the Agency has
recently tested the destruction efficiency of catalytic incineration for
various VOC  (see EPA-600/2-85-041).   In this study, the Agency examined vent
streams similar in characteristics to the commenter's vent stream.  The
results show that VOC destruction efficiencies greater than 98 percent were
achieved with temperatures ranging from 800°F to 900°F and residence times
ranging from 0.07 to 0.12  seconds.  Thus, the Agency believes that catalytic
incinerators can achieve 98 percent VOC destruction efficiency and does not
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believe the commenter will  need to Install  a thermal  incinerator after a
catalytic oxidizer.

2.3  MODIFICATION

     2.3.1 COMMENT:  One commenter (D-5) stated that the proposed regulation
would apply to any air oxidation reactor which is modified such that there is
an increase in the amount of any air pollutant emitted into the atmosphere.
The commenter pointed out that this could include a reactor which is modified
such that VOC emissions are decreased, but emissions of another pollutant are
increased.  The commenter recommended that the modification provisions be
amended to include consideration of the following: (a) the specific pollutant
which causes the process change to become a modification, (b) the amount of
the increase in emissions,  (c) the cost of the process change, and (d) the
level of control prior to the process change.

     RESPONSE:  The General Provisions, 40 CFR 60.14, define a modification
as "any physical or operational change to an existing facility which results
in an increase in the emission rate to the atmosphere of any pollutant to
which a standard applies" (emphasis added).  In the case of the air oxidation
regulation, the only pollutant to which the standard applies is VOC; there-
fore, only increased VOC emissions would result in an existing facility
becoming subject to the NSPS modification provisions for air oxidation
processes.  However, a modification which results in the increase of another
pollutant may cause a facility to have to comply with the provisions of
another part of the CAA such as prevention of significant deterioration  (PSD)
or SIP requirements, or a different NSPS for a pollutant other than VOC.

2.4  ECONOMIC IMPACT

     2.4.1 COMMENT:  One commenter (D-7) stated that the economic feasibility
threshold of 20 percent of total plant capital cost used in the economic
analysis is too high.  This commenter stated that the chemical industry  is
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already devoting 10 to 15 percent of capital  investment in new plants to
overall pollution control.  This commenter pointed out that it is
unreasonable to set an economic feasibility threshold for one type of
pollution from one emission point at a level  comparable to the total
environmental control costs.  Specifically, this commenter recommended that
the cutoff figure be based on total  capital costs for all forms of pollution
control at air oxidation facilities.

     RESPONSE:  The economic impact of air oxidation NSPS controls is a
function of the effects of the costs of compliance on the profitability of
air oxidation projects and on the availability of capital for those projects.
Profitability is the preferred measure of impact because of the profit
maximizing objectives of firms.  Implicit in the profitability measure is the
likelihood that if a project meets profit objectives, the capital will become
available.
     The profitability analysis showed that air oxidation NSPS controls would
not render projects economically infeasible that were otherwise economically
feasible.  An explicit capital availability measure was also applied to see
if there might be circumstances where, regardless of expected profits, a firm
would  find it hard to raise the necessary funds for a project.  The capital
availability analysis showed that only one chemical might, under worst-case
cost assumptions, be produced under conditions where the capital control
costs  exceed 20 percent of  uncontrolled plant costs.
     Unfortunately the Agency did not, and does not, have adequate, reliable
data on the  costs of building uncontrolled plants for all air oxidation
processes.   Reliance was  placed on  proprietary process economics data  from
Stanford Research  Institute (SRI),  but it was not possible to fully match
SR'I's  plant  parameters with those in  the national statistical profile  data
base used to develop the  air oxidation NSPS.  Worst-case  assumptions were
made to ensure conservative results.  The  results of the  capital availability
analysis were  used to  identify  chemicals  and processes that warranted  closer
examination.
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     The analysis found only one chemical  that might have capital control
costs in excess of 20 percent of uncontrolled plant costs.  It is
1,3-butadiene.  Over 85 percent of 1,3-butadiene capacity utilizes nonair
oxidation processes (extraction from ethylene plant by-product streams and
dehydrogenation of n-butane).  New plants are expected to be all ethylene
by-product extraction plants.  Only one air oxidation process is used today;
this is the oxidative dehydrogenation of n-butenes.  The July, 1983
Mannsville Chemical Products Synopsis on butadiene, and the SRI 1983
Directory of Chemical Producers report that only two firms used this process
in 1982.  One is the Firestone Synthetic Rubber and Latex Company, but it
recently closed the plant, which was in Orange, Texas.  The only remaining
firm, Petro-Tex Chemical Corporation, operates a facility in Houston, Texas.
However, Report 7 of Organic Chemical Manufacturing, Volume 10: Selected
Processes (EPA-450/3-80-028e) states that the vent stream at this plant is
controlled by a thermal oxidizer.  Thus, it appears that no new, modified, or
reconstructed 1,3-butadiene facility will  have to install control equipment
as a result of this NSPS.  The future facilities either will be nonair
oxidation, or will be in a situation where control would be installed even in
the absence of this NSPS.
     With more complete process economics data EPA could look into possible
capital availability problems in more depth and for more of the air oxidation
chemicals.  Unfortunately, the needed information was not provided by this or
any commenter.
     The Agency also believes that the TRE cutoff will prevent situations
where capital control costs become unduly large.  The capital cost of an
incinerator and associated equipment is mostly a function of the vent stream
flow rate and the presence of halogenated compounds, which necessitates
scrubbing.  A high flow rate results in a high capital cost of control and a
high TRE.  Other things remaining unchanged, as the flow rate increases, the
capital control costs as a percentage of the cost of an uncontrolled plant
will increase, but so will the TRE value until the TRE cutoff is reached and
control is no longer required.  Because all other things do not remain
unchanged, it is not possible to establish an unambiguous relationship
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between the TRE cutoff and a corresponding cutoff percentage of plant costs
that must go toward control equipment.   However,  it is clear that the TRE
cutoff can, in rare instances where actual (not worst-case) capital control
costs may exceed 5 or so percent of uncontrolled plant costs, serve to limit
that percentage.  Of course, one can postulate an extraordinarily cheap and
inefficient plant - one that produces more CO, C02, H20, and corrosive
waste, than product -- where the TRE cutoff will not serve as a check on
capital  control costs as a percentage of  uncontrolled plant cost.  The EPA
does not consider such plants as likely.
     The commenter  also recommended that  any criterion relating to capital
constraints  be based  on the total  capital  costs  for  all  forms  of  environ-
mental  pollution  control.   Section 8.2  of the  BID (EPA-450/3-82-001a)
discusses the overall  burden of environmental  regulations  on firms that  may
 be affected by the air oxidation NSPS.   This  discussion  centers on total
 annualized costs; that is, on capital  and annual operating costs combined.
 The EPA believes these annualized costs more  accurately  represent potential
 burden on affected firms than do capital costs.
      In short, EPA believes this NSPS will not impose unduly restrictive
 capital problems on any segment of the chemical industry.

      2  4.2 COMMENT:  One  commenter (D-9)  stated that some plants  have been
 inaccurately recorded in  the BID.  This  commenter listed  Shell Chemical
 Company plants that  are  either no longer producing  an air oxidation chemical
 or have changed  to nonair oxidation processes.   Finally,  this  commenter
 stated that if these inaccuracies are  widespread,  a review of basic data  may
 be advisable to ensure  that they support the  NSPS.

    -   RESPONSE:  Given that one of the earliest stages in the regulatory
  standard-setting process  involves data collection, it is not surprising that
  some of the data are no  longer current.  Although the BID was published  in
  October 1983, many of the data go back to 1978.  Continual updating is
  expensive and can be unnecessarily burdensome to companies and trade groups
  that participate  in the  cost  updating procedure.   For this reason, generally
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EPA only updates data considered essential  to support the NSPS.   For other
data, EPA relies on comments submitted by companies like Shell  Chemical  to
decide whether updating is necessary.   It should be noted that  Shell
submitted the only comment in this regard.   Thus, although it would be nice
to have the list of producers of air oxidation chemicals current as of today,
the list of producers has minimal bearing on the economic impact analysis and
the standard itself.  The EPA concludes that there is no need to update the
list of producers or the economic impact analysis.

2.5  COST ESTIMATION

     2.5.1 COMMENT:  One commenter (D-2) recommended that all costs discussed
in the preamble be inflated from 1978 dollars to fall 1983 dollars.  This
commenter indicated that the cost-effectiveness cutoff would then become
$2,600/Mg instead of $l,900/Mg.

     RESPONSE;  The Agency agrees that the cost-effectiveness cutoff of
$l,900/Mg (December 1978 dollars) would be about $2,600/Mg in fall  1983
dollars.  However, EPA maintains that this would not change the analysis or
the requirements of the standards.  When the analysis for the air oxidation
NSPS was begun, it was decided that 1978 would be the appropriate base year
for costs because more recent data were not available.  If the implicit price
deflator for the gross national  product is applied, the cost-effectiveness
cutoff inflates 40 percent over  the 5-year period.  However, regardless of
whether it is expressed in 1978  or 1983 dollars, the cost-effectiveness
cutoff has the  same impact.  If  a given facility cost effectiveness is
increased 40 percent by an inflation factor to $2,600/Mg, the cost-
effectiveness cutoff will also increase by 40 percent, since both values are
calculated using the same cost assumptions.  Thus, the ratio will remain the
same, and the TRE  index cutoff value will still  be 1.0.   Inflation  does not
affect the validity of the TRE index.  Furthermore, in considering  an
inflated TRE cutoff, it should also be realized  that the  value of the
benefits associated with the standards are also  inflated  accordingly.  Thus,
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EPA plans no change in the base year dollars for the costs discussed in the
preamble.

     2.5.2 COMMENT:  Two commenters (D-2 and D-7, D-14)  stated that several
oversights and flawed assumptions exist in the cost estimation procedure.
Both commenters asserted that capital  cost estimates allow for only 150 feet
of ductwork between the source and the thermal incinerator, although 300 to
500 feet would generally be required.   Both commenters also indicated that
EPA failed to include in the capital cost component the total  cost of siting,
bringing utilities to the site, and piping and instrumentation connections.
One commenter (D-2) stated that the capital cost estimate should be increased
by at least 10 percent to account for these oversights.   In addition, both
commenters mentioned operating costs that were ignored include maintenance-
related labor costs, operating supplies, and laboratory costs.  Both
commenters suggested that a factor'of 40 percent of maintenance and operating
labor be added to compensate for these oversights, as was done in the BID for
petroleum refining operations.  One commenter (D-7, D-14) also asserted that
annualized costs should include an allowance of 15 percent of labor costs for
direct supervision, as listed in the BID for polymer manufacturing.

     RESPONSE:  In response to these statements claiming that the costing
procedures contain flawed assumptions, the Agency reviewed the procedures  in
great detail.  Revisions were made where determined to be.appropriate for
ensuring that the costing procedures result in representative costs.
Throughout the development of the air oxidation NSPS the Agency has made
efforts to ensure that the costing procedures result in estimates that
adequately represent control costs anticipated to be incurred by the majority
of facilities in the industry.  Prior to proposal,  industry members were
given the opportunity to provide substantial  input  into the development  of
the costing procedures.  Preliminary costing  assumptions were reviewed by
industry and  subsequently revised based upon  industry input.  After  proposal,
costing  assumption  revisions were prepared  and presented  in a supplemental
Federal  Register notice  (50  FR  20446) on May  16,  1985.  This  notice  solicited
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further comments on costing procedures.  The bases for these revisions are
documented in Docket Item No. IV-B-8.  As a result of the initial industry
involvement and the recent revisions based on industry public comments, the
Agency feels confident that the costing procedures result in accurate
estimates for typical air oxidation facilities.  The specific assumptions
that are key for ensuring representative cost estimates are discussed below.
     Certain assumptions were included in the procedures to avoid
underestimating costs incurred by facilities using combustion to control VOC.
These assumptions were made to ensure that control equipment sizes and
supplemental gas requirements were not underestimated.  First, vent streams
were assumed to contain no oxygen to maximize estimated combustion air
requirements.  Most streams, while not containing 21 percent oxygen, have
some smaller percentage of oxygen present.  The assumption of no oxygen
ensures that no underestimate will occur for the equipment size, the combus-
tion air flow rate, and the amount of supplemental natural gas needed.
Second, actual offgas flow rate was increased by 5 percent in calculating
costs, which inflated gas consumption and equipment size by 5 percent.
Third, the temperatures and residence times assumed for cost estimation
purposes (l,600°F/.75 sec for nonhalogenated streams, 2,000°F/1 sec for
halogenated streams) are the highest temperature and residence time
conditions necessary to achieve a 98 percent VOC destruction efficiency for
air oxidation vent streams, as discussed in Appendix A of the proposal BID.
These higher temperatures and residence times would result in a larger
equipment size and higher gas consumption than the majority of air oxidation
facilities require.  Fourth, the overall installation factors assumed for new
sources were 4.0, 2.5, and 3.5 for the combustion chamber, heat exchanger,
and waste heat boiler, respectively.  These factors were all higher than the
EPA CARD Manual recommended factor of 2.17 (EPA-450/5-80-002) because they
incorporate contingencies recommended by the industry to account for
equipment that was not originally specified in the costing procedure.
     Revisions were made where appropriate in the capital cost and the annual
operating cost assumptions used in the procedures.  For example, in the
capital cost component of the procedures, the ductwork length was changed
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from 150 feet to 300 feet.  The ductwork length increase is based on
specifications provided by the Industrial  Risk Insurers (IRI)  and the
National Fire Protection Association (NFPA).   These organizations present
recommended distances for safely locating combustion sources from process
units in chemical plants.  The recommended distance for locating a closed
combustion source such as an incinerator from a process unit is 200 feet.  An
additional 100 feet was added to the IRI and  NFPA recommendation to account
for routing the stream around process equipment before routing it away from
the process unit.  The 300-foot figure is believed to be more representative
of industry conditions and is within the range recommended by the commenter.
     In addition to the ductwork length change, the capital cost component of
the procedures also was modified to include 250 feet of pipe rack.  The
Agency judged that since the standards will probably require the use of new
rather than existing incinerators and since newly constructed incinerators
would require about 300 feet of ductwork, it  is reasonable to assume that
existing structures may not be available to support the piping.  However, the
250 feet of pipe rack assumes that 50 feet of the 300 feet of ductwork would
be supported by existing structures.
     Several revisions were also made in the  annual operating cost component
of the procedures.  These were revisions in the labor rate, in the calcula-
tion of total labor cost, and in the gas and  electricity prices used.  All
these annual operating cost revisions are discussed below and are explained
in more detail in a memorandum to the SOCMI air oxidation NSPS files (Docket
Item No. IV-B-8).  The labor rate was changed to reflect more accurately the
actual value for 1978.  The original incinerator labor costing was based on a
labor rate  (including overhead) in 1979 dollars that was deescalated to  1978
dollars.  The new labor rate is based on actual U. S. Bureau of Labor
Statistics  for 1978 and does not include overhead and fringe benefits.
     The revisions in the calculation of total labor cost were made to
explicitly  calculate the cost attributable to overhead and fringe benefits.
The overall changes in the total labor cost calculation included:
(1) calculation  of the supervisory labor cost as 15 percent of the operating
labor cost;  (2)  calculation of the overhead cost as 80 percent of the sum of
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operating, supervisory,  and maintenance labor costs;  and (3)  calculation of
total labor cost as the sum of operating,  supervisory,  maintenance, and
overhead labor costs.
     The natural gas price used in the costing procedures was revised to
represent more accurately the projected effects of natural gas deregulation
and account for regional variations in gas price.  The previous estimate of
natural gas was based on prices projected through the first 5 years of the
regulation and then was deflated to 1978 dollars.  This was done to reflect
the fact that gas prices have been rising more rapidly than inflation.  The
previous estimate was made during a period of rapidly increasing energy
prices.  However, the actual rate of increase has slowed since that original
estimate was made.  Thus, to improve the accuracy and representativeness of
the gas price, a new projection was made.  The gas price was derived by
projecting regional gas prices to 1990, taking a nationwide 1990 gas price
that was weighted geographically, and then deflating to 1978 dollars.
     The price for electricity was modified to provide for a more accurate
estimate of 1978 costs.  Although the electricity was originally based on
1978 costs, further examination showed that a more representative price could
be used.
     Several of the commenters' suggestions were not incorporated in the
procedures because they were not justified.  The recommended capital cost
items that were judged to be inappropriate included the costs for siting,
bringing utilities to the site, and piping and instrumentation connections.
The  cost associated with bringing utilities to the site was not included
because the control device will be located in the proximity of the process
unit where utilities are readily accessible.  It was not necessary to  include
the  cost for siting because this has already been included.  An equipment
cost installation factor of 1.35, which increased equipment purchase price  by
35 percent, was used to account for site development, fees, and general
contingencies.  Neither was it necessary to include the cost associated with
piping and instrumentation connections, because  these were already incor-
porated.  An equipment cost installation factor  of 1.20 was used to  increase
the  equipment  purchase price by 20 percent to account for unspecified
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equipment.  Also,  an overall  correction factor of 1.33 was used to increase
equipment purchase price by 33 percent to account for any miscellaneous items
associated with purchasing and installing control equipment that may have
been overlooked.
     Some annual operating cost items recommended by the commenters were also
judged to be inappropriate.  The items identified by the commenters included
maintenance-related labor costs, operating supplies, and laboratory costs.
It was not necessary to include maintenance-related labor costs because these
are already incorporated in the maintenance labor factor, which is calculated
as 3 percent of the total installed capital cost.  Similarly, the cost
associated with operating supplies was not a missing item but was already
incorporated in the maintenance materials factor, which is calculated as
3 percent of the installed capital cost.  Finally, it was determined that
laboratory expenses, such as those involved with testing scrubbing wastewater
effluent, are part of the normal operating and maintenance cost for an
incinerator/scrubber system that would be used to control vent streams with
halogenated compounds.  Thus, factors for maintenance labor and maintenance
materials associated with such a system would incorporate laboratory
expenses.
     In summary, the revised costing procedures do not result in annualized
costs that are  significantly different from the costs estimated using the
procedures used at proposal.  An examination of the data showed that
depending on the vent stream characteristics of a facility, the annualized
cost increased  for some facilities and decreased for others.  For the most
common type of  air oxidation vent stream  (Category B - nonhalogenated stream
with net  heating value below 0.48 MJ/m3), the annualized cost increased by
about 3 percent.

     2.5.3 COMMENT:  Two commenters  (D-2  and D-7) identified two
discrepancies  in the cost  information presented  in the proposal BID.  First,
for a given set of vent  stream  characteristics,  the total capital cost
obtained  from  Figures 6-1, G-2, and  G-4 does not  agree with the total capital
cost obtained  from Figure  6-9  (a_composite of Figures 6-1, G-2, and G-4).
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For example, the commenter refers to a case based on a 10,000 scfm,
10 Btu/scf, Category B stream with 70 percent recuperative heat recovery.  In
this situation, the capital cost obtained from Figures G-l, G-2, and G-4 is
$922,000, while the capital cost obtained from Figure G-9 is $850,000.  One
commenter (D-2) noted a second discrepancy between the annualized incinerator
cost components given in Tables 8-5 and 8-7 of the BID and those used in
Table E-2.  This commenter said that the investment multiplier in Table E-2
is higher than the investment multiplier in Table 8-5.  Although the
annualized costs listed in Table E-2 appear to be in mid-1980 dollars, the
hourly rate for labor is lower.

     RESPONSE;  The Agency acknowledges the discrepancy noted by the
commenter concerning total installed capital costs obtained from Figures G-l,
G-2, G-4, and G-9.  Upon checking the original data from which these graphs
were derived, the Agency has determined that the costs obtained from the
summation of the graphs showing individual component costs (i.e., G-l, G-2,
G-4) are correct.  The composite graph (i.e., G-9), which should give the
aggregate of the total installed capital costs obtained from the individual
component graphs, is incorrect.  However, even without correction, the
impacts of this error in the graph showing installed capital cost on the
total annualized cost would be relatively small.  The impacts would be
relatively small because:  (a) the error in the graph showing installed
capital cost is relatively small for most vent streams; and  (b) the installed
capital cost, when annualized over the 10-year period, represents a small
fraction of the total annualized cost.  Nevertheless, the Agency modified the
cost equations to correct the small discrepancy.  The Agency has also revised
the table of TRE coefficients to make the TRE index equation reflect these
changes.  A corrected copy of Table 8-5, which presents the capital cost
coefficients used in the cost equation, will be presented  in Appendix B of
the promulgation BID.
     The Agency also acknowledges the discrepancy noted by commenter  (D-2>
concerning cost factors given in Tables 8-5, 8-7, and E-2.  The cost factors
presented  in Tables 8-5 and 8-7 are correct.  The information presented  in
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Appendix E comes from a similar appendix prepared for the air oxidation
Control Techniques Guideline (CTG) document.   The cost factors from
Tables 8-5 and 8-7 were used in developing the TRE equation and coefficients
presented in the proposal regulation.  However, it should be noted that some
of these factors have been revised.  As indicated in the previous response
the gas, labor, and electricity factors were  modified to improve the accuracy
and representativeness of the cost algorithm.  These changes are explained
and documented in a memorandum to the SOCMI air oxidation NSPS docket (Item
No. IV-B-8).  A corrected version of the appendix concerning TRE calculations
will be included in Appendix A of the promulgation BID.  The cost factors
presented in the CTG have also been revised so that they are on a consistent
basis with the factors used in the air oxidation NSPS algorithm.

     2.5.4 COMMENT:  Two commenters (D-2 and  D-7) disagreed with the
assertion in the preamble that annualized costs associated with the disposal
of sodium chloride from scrubbing incinerator flue gases containing halo-
genated compounds are insignificant and, therefore, are not included in the
cost estimates.  Both commenters stated that  disposal will be expensive
unless the plant is located near salt water and can get a permit to dump its
brine.

     RESPONSE:  Brine solutions are currently disposed of in a variety of
ways depending on site-specific conditions.  These include direct discharge
to sewer systems and surface waters (fresh and salt water bodies or rivers),
discharge to evaporative lagoons, and injection into a disposal well.
Because it is not possible to determine which options will be selected by the
individual facilities analyzed, it would be  impractical to represent all of
these types of brine disposal in the cost, analysis.  Therefore, the costs
anticipated to occur at the majority of facilities handling halogenated
compounds were considered instead.
     Data available to the Agency shows that most air oxidation plants
producing halogenated waste streams are located near the coast  (see Table 3-6
of the Air Oxidation proposal BID,) where brine can be disposed of at a low
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cost either directly or indirectly into salt water (e.g.,  ocean or brackish
stream direct discharge).   The Agency believes that most new,  modified, and
reconstructed facilities will  continue to use this relatively  low cost
disposal option.  For those few that may not, EPA believes the other
relatively low cost options will be used (e.g., fresh water or sewer
discharge) since available data show that industrial facilities with waste
streams similar to those from air oxidation plants are currently using these
disposal options extensively.   Therefore, the Agency has no reason to believe
that any air oxidation facility will face a significant brine  disposal cost
as a result of this NSPS (Docket Item No. IV-B-9).

2.6  COST EFFECTIVENESS

     2.6.1  COMMENT;  Three commenters (D-2, D-6, and D-7, D-14) indicated
that the $l,900/Mg cost effectiveness cutoff is unreasonable.   One commenter
(D-6, D-6a) recommended that the cutoff be raised to a level higher than
$l,900/Mg so that the standards cover a greater number of emission sources
and, thus, a greater amount of emissions.  This recommendation is based on
the commenter's perception that the inclusion of a greater number of sources
would reduce public exposure to pollutants emitted by air oxidation reactors,
including potentially hazardous pollutants.  This commenter also stated that
cost effectiveness is inappropriate as the sole determinant for excluding
certain air oxidation reactors from the application of the proposed
standards.  The commenter stated that cost effectiveness is an invalid basis
for deciding not to set standards on processes for which no perceptible
economic impacts have been shown.  Two commenters (D-2 and D-7) stated that
the cost-effectiveness cutoff should be reduced to a lower level which is
more typical of VOC standards.  Both commenters stated that the Agency has
not presented adequate justification for concluding that a $l,900/Mg cost-
effectiveness cutoff is a reasonable upper limit for application of the
standards.  Specifically, these commenters assert that this higher figure
cannot  be justified based on the presence of toxic constituents in the
discharge streams from air oxidation reactors.  They point out that the
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control of toxic pollutants 1s the objective of standards developed under
Section 112 of the CAA [National Emission Standards for Hazardous Air
Pollutants (NESHAP)] and not standards such as these which are being proposed
pursuant to Section 111 of the Act (NSPS).  The first commenter (D-7, D-14)
stated that the Agency:  (1) has not presented data which quantifies the
presence of toxic pollutants in the emissions from air oxidation processes,
(2) has made no effort to correlate the costs of control with the degree to
which toxic pollutants are eliminated, and (3) has not shown that toxic
pollutants will be controlled to the same degree as other pollutants under the
proposed standards.  The second commenter (D-2) contended that the preamble
does not adequately demonstrate that the presence of toxic pollutants in the
emissions from air oxidation reactors are sufficiently different from the
emissions from other VOC sources to justify a special consideration of their
hazards.  Both commenters also state that although the cost of controlling VOC
emissions is analyzed as a "worst-case" situation, there are facilities which
will have to incur costs as high as $l,900/Mg.  They contend that the Agency
has not justified costs this high as being either reasonable or appropriate
for these facilities.

     RESPONSE;  The EPA believes that its decision to consider cost-
effectiveness when determining the cutoff for applying the standards reflects
a reasonable interpretation of Section 111 of the CAA.  In analyzing the
question whether the consideration of cost effectiveness is appropriate, EPA
looked to see whether Congress has "directly spoken to the precise question."
Chevron. U.S.A.. Inc. v. NRCD. 467 U.S. 837, 104 S.Ct. 2778, 2782 (1984).
Section 111 requires EPA to promulgate NSPS limiting emissions to the level
that reflects the best system of emissions reduction "which (taking into
consideration the cost of achieving such emission reduction, any nonair
quality health and environmental impact and energy requirements) the
Administrator determines has been adequately demonstrated."
Section lll(a)(l).  Nothing in either Section 111 or elsewhere in the Act
defines "the cost of achieving such emission reduction."  The plain meaning of
the phrase, however, is quite broad.  This indicates that Congress implicitly
delegated to EPA the authority to interpret the phrase to encompass a range
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  of Impacts,  Including  costs  of control  In  relation  to  the  emission  reduction
  achieved.   Further,  Congress did  not  specify any particular manner  in which
  EPA was  to  take  these  costs  "into consideration."   Thus, absent a clear
  Congressional direction to the  contrary discernible from the Act's  history
  Chevron, 104 S.Ct. at  2783, Section 111 gives EPA authority to reject NSPs'
  control  options on the ground that their costs are unreasonably high in light
  of  the emissions reductions they  achieve.  I/
      The EPA has reviewed the legislative history of Section 111 and concluded
  that no contrary intent is discernible.  Most important, the history contains
  no express repudiation of the use of cost effectiveness as one mechanism in
 considering cost when setting an NSPS.
      For these reasons, EPA believes that Congress  implicitly  delegated  the
 Agency the authority to decide  how best to "take  into consideration...cost"  in
 setting NSPS and,  if the Agency concluded it  was  appropriate,  to consider  cost
 effectiveness.
     Further»  1n  Portland  Cemomt Association  w  T^I,,  513  F.2d 506> 508 (Q c
 dr. 1975),  cert, denied,  416 U. S.  1025  (1975) ("Portland  if), the Court
 stated  that  EPA may reject control options  that result  in a "gross
 disproportion between achievable reduction  in emissions  and cost of  the
 control technique."  Since the purpose of cost-effectiveness analysis is to
 highlight such disproportion, this passage supports EPA's approach.
     In selecting cutoffs  related  to applicability of NSPS, EPA looks at a
 variety of factors including:  (1) the technical  feasibility of additional
control;  (2) the economic feasibility associated  with different control
alternatives; (3) the magnitude  of emission reductions associated with  a
control  alternative (e.g.,  a slightly higher cutoff  could be selected if  it


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led to a substantial Increase In the emission reduction achieved by the NSPS);
(4) the cost effectiveness (C/E) of the control alternative in terms of annual
cost per megagram ($/Mg) of emissions reduced; (5) the quality of the cost
estimates (e.g., worst case versus realistic estimates); (6) potential
reductions in other air pollutants not specifically regulated by the NSPS
resulting from a control alternative; and (7) the location of the sources
(e.g., urban versus rural).  Because these factors vary from industry to
industry and, in some cases, within the same industry, decisions on the
appropriate level of control are made on a category-by-category basis.
     In evaluating the above factors, EPA found that the following
considerations were key to the selection of the appropriate cutoff for SOCMI
air oxidation processes:  (1) the cost effectiveness of NSPS for VOC emissions
previously promulgated by the EPA; (2) the fact that air oxidation vent
streams contain compounds that are considered potentially toxic by EPA; and
(3) the likelihood that these maximum costs will  not be incurred by industry.
     A survey of the VOC standards for other source categories shows that the
cost effectiveness of those control requirements has sometimes ranged as high
as $2,000/Mg.  (See Docket Item No. IV-B-14.)  The Agency's experience in
implementing these standards reveals that NSPS requiring this level of control
have proved a useful tool in bringing about the installation of much emissions
control technology, significant reductions in emissions, and corresponding
improvements in air quality, yet have not imposed costs that appear "grossly
disproportionate" to the emission reduction achieved.  Portland II. 513 F.2d
at 508.  Such an approach simply makes this NSPS consistent (as to dollars
spent per metric ton of VOC removed) with the existing body of NSPS
regulations, all of which have either been promulgated without legal challenge
or have been judicially upheld.
     EPA also considered available evidence that air oxidation streams include
compounds that may be toxic.  2/  Although that evidence has not yet resulted
2/ The Agency has adequately documented that this is the case.  (See Wehrum,
W. et a"!., "Air Toxics Emission Patterns and Trends", Docket Item No. IV-A-3,
and Registry of Toxic Effects on Chemical Substances, Docket Item
No. IV-J-9).  Moreover, it is apparent that combustion of those streams will
reduce those compounds proportionately.  (See, e.g., "Thermal Incinerator
Performance for NSPS", Docket Item No. II-B-3).  The Agency received no
comment questioning this documentation.

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in a determination that those compounds should be listed as hazardous under
Section 112, EPA considered this potential  toxicity along with other relevant
factors when choosing the cutoff.  As stated in EPA's Air Toxic Strategy
published in July 1985, the Agency will consider the likely toxic pollutant
control benefits in the course of carrying out its responsibilities under
Section 111.  This strategy reduces emissions of potentially toxic compounds
from new sources and from industries as their facilities are reconstructed or
modified.  This approach achieves significant reductions in these compounds of
concern while the Agency evaluates them for regulation under Section 112.  The
Agency disagrees with the argument that EPA has no authority to do this.  The
EPA is not attempting here to regulate streams based on a decision that they
contain hazardous air pollutants within the meaning of Section 112.  Rather,
the Agency is simply considering all available evidence within the framework
of Section 111.  Section 111 does not attempt to restrict EPA's discretion to
consider all relevant factors in making that decision, and certainly the
potential toxicity of a stream is relevant to the control requirement
selected.  Many SOCMI facilities are located in urban areas and, as a result,
many people will be exposed to any hazardous air pollutants emitted from these
facilities,
     A third consideration in setting the cutoff at $l,900/Mg is the
likelihood that no facility will actually have to incur the costs implied by
that cutoff.  The reasons are:   (a) less expensive combustion control may be
used, thus reducing the costs and cost effectiveness incurred by individual
facilities; (b) the cost estimates for thermal incinerators and natural gas
prices are overstated; and (c) the inherent flexibility within the regulation
encourages the use of product recovery modifications that will significantly
reduce the cost incurred by individual facilities that may have otherwise had
to add a combustion device.  The regulatory analysis assumes that each air
oxidation process vent would have its own combustion device and would need
separate ducting and support structures.  It is expected, however, that some
air oxidation processes will share control systems with other process vents.
The analysis also assumes that thermal incinerators or flares will be useful
to reduce VOC emissions by 98 weight-percent.  Data on current capital costs
of thermal incinerators indicate that units are now available at substantially
                                     2-35

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reduced costs compared to the costs used in developing these standards.  Lower
capital costs would reduce the annualized costs estimates,  also,  but not as
significantly.  This is an important consideration in selecting the
appropriate cost-effectiveness cutoff.   Another consideration is  the fact that
natural gas prices used to calculate the cost-effectiveness for each stream
are overstated by about 40 percent, even though they were updated after
proposal (see following section on "Costing Revisions").  These conservative
assumptions have resulted in higher cost and cost-effectiveness estimates than
will actually occur.  Finally, the standard encourages pollution  prevention by
not requiring 98 weight-percent reduction if a TRE index greater  than 1.0 is
maintained.  The EPA believes that many facilities having a TRE index just
below the 1.0 cutoff (equivalent to $l,900/Mg) will upgrade product recovery
to reduce VOC and raise their TRE index above 1.0.  This will significantly
reduce the cost of control incurred by the industry while reducing emissions
and will also minimize the national energy impacts.  A preliminary examination
of the national statistical profile shows that because many facilities have
the potential to reduce VOC emissions sufficiently to raise their TRE values
above 1.0, the highest cost effectiveness that a facility will actually incur
as a result of installing a combustion device is estimated to be approximately
$l,400/Mg.
     The EPA believes that this process reflects a reasoned interpretation of
the phrase "taking into consideration the cost of achieving such  emission
reduction," especially given the lack of clear Congressional guidance.  The
commenters' arguments that EPA should have selected either a higher cutoff to
provide for a greater degree of protection of the public health,  or a lower
cutoff because most VOC standards have lower costs in relation to the
resulting emission reduction, fail to provide a more reasoned methodology for
selecting the appropriate level.   Instead, they merely reflect each of the
competing goals reflected in Section Ill's history, as described above.
     Consideration of all of the above factors confirmed EPA's belief that a
TRE value of  1.0  (i.e., $l,900/Mg) represents an appropriate cutoff for
determining which facilities must reduce VOC emissions by 98 weight-percent or
to 20 ppmv.   The  cutoff is specific to the SOCMI air oxidation processes
sources category  and would not necessarily be appropriate for other source
categories; therefore, it should not be viewed as  a benchmark for other
standards.
                                     2-36

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     2.6.2  COMMENT:  One commenter (D-5) stated that the incremental cost and
energy impacts of requiring 98 percent control versus 95 percent control of
VOC emissions from affected facilities should be investigated further.
Specifically, the commenter believes the Agency should consider that source-
specific conditions such as fuel value, temperature, and volume vary widely.

     RESPONSE:  The Agency has determined that 98 percent destruction
efficiency represents BDT.  In determining the level of control which
represents BDT, the Agency examined emissions data from incinerators already
operating within the industry as well as incinerator tests conducted by the
Agency and by chemical companies.  The data show that all the new, well
operated incinerators were achieving 98 percent destruction efficiency or
could achieve 98 percent after adjustment.  The Agency also found that at the
lower temperature and shorter residence time required for lower efficiencies,
some VOC may not come into contact with sufficient oxygen at a high enough
                                     2-36a

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temperature to enable the oxidation of VOC to proceed to completion.  As a
result, there is greater chance that partially oxidized organic compounds
(e.g., aldehydes) and carbon monoxide may be generated.
     As indicated in the response to comment 2.2.3, the air oxidation
standards are structured in a way which prevents any facilities from
incurring an unreasonable cost effectiveness.  The Agency has found that
because of the wide variation in vent stream characteristics, both the cost
and cost effectiveness of control may vary considerably depending on the
chemical and the process.  Further, the Agency has determined that the cost
of control would be unreasonable for some facilities.  Consequently, the
standards are structured with the TRE index cutoff to require only those
facilities that can control cost effectively to achieve a 98 weight-percent
reduction efficiency or reduction to 20 ppmv.
     The Agency recognizes that there are source-specific characteristics
(e.g., market conditions, process design, and geographic conditions) that may
impact the cost of VOC emissions control for individual facilities.  To
address the source-specific characteristics would have required separate
standards for each facility reflecting the differences in source-specific
characteristics.  The Agency is unable with the available information and
resources to evaluate all source-specific characteristics of each facility
that could potentially be affected by the air oxidation NSPS.

2.7  MONITORING AND MEASUREMENT METHODS

     2.7.1 COMMENT:  One commenter (D-7) stated that the requirements for
continuous monitoring of VOC are unclear.  This commenter indicated that the
proposed NSPS could be read to require continuous monitoring even during
periods of start-up and shutdown.  Specifically, this  commenter pointed out
that this interpretation is arbitrary and inconsistent with  the EPA general
enforcement policy.  This commenter  said that EPA  regulations  normally allow
for temporary excursions due to  start-up and shutdown.
                                     2-37

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     RESPONSE:  The General Provisions, at 40 CFR 60.8(c), do allow for
temporary excursions due to start-up and shutdown of the affected facility.
This means that emission levels during these periods are not counted as
violations if they exceed the levels specified in the regulation.  This does
not mean that a facility is exempt from monitoring requirements during these
periods; on the contrary, Section 60.13(e) states that "except for system
breakdowns, repairs, calibration checks, and zero and span adjustments . . .,
all continuous monitoring systems shall be in continuous operation."  In
addition, Section 60.11(d) states that any affected facility and associated
air pollution control equipment must, to the extent practicable, be main-
tained and operated at all times, including periods of start-up, shutdown, or
malfunction of the affected facility.  Monitoring is necessary to determine
how often and for how long periods of start-up, shutdown, or malfunction
occur and to assure that the affected facility and control device are being
operated in a manner consistent with good air pollution control practice for
minimizing emissions.  Determination of whether acceptable operating and
maintenance procedures are being used will be based, in part, on monitoring
results.  Therefore, it is essential that monitoring be conducted
continuously.

     2.7.2 COMMENT; .One commenter  (D-ll) agreed with EPA and stated that  it
is appropriate to waive performance tests and monitoring requirements for
sources incinerating process vent streams in steam generating devices that
have heat input capacities of 44 MW  (150 million Btu/hr) or greater.  This
commenter suggested that the following conditions be required for exemption
from performance testing and monitoring requirements: (a) boilers with heat
input capacity of 44 MW (150 million Btu/hr) or greater,  (b) combustion
devices maintaining a combustion temperature of 1,100°C and 1 second
residence time, and (c) incineration devices maintaining a temperature of
870°C and 0.75 second residence time if no halogenated organic compounds are
present in the vent gas.
                                    2-38

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     RESPONSE;  The EPA believes that condition (a)  mentioned by the
commenter is sufficient for exemption from performance tests.  However,
conditions (b) and (c) mentioned by the commenter are not sufficient.  An
incineration device operated at temperatures greater than 1,100°C and
1 second residence time (870°C and 0.75 second residence time for non-
halogenated streams) will  achieve a 98 percent VOC reduction providing that
proper mixing has been achieved.  The reactor offgas, combustion gases, and
supplemental air must be well mixed in order to achieve complete combustion.
The EPA has determined that proper mixing is, in fact, as important as
temperature and residence time in determining incinerator efficiency.  This
concept is explained in an EPA memorandum (Docket Item No. II-B-3).
Improperly mixed gases may actually offset the increases in efficiency
generated by raising the combustion temperature.  This is due to the fact
that increases in temperature only increase the destruction efficiency for
VOC within the well-mixed portion of the waste gas.   In an improperly mixed
stream, therefore, the increase in temperature does not greatly affect
combustion efficiency.
     Unfortunately, mixing is a variable which cannot be measured.  Proper
mixing is generally achieved through a trial-and-error process of adjusting
the incinerator after start-up.  There is no practical method of ensuring
that proper mixing occurs except by conducting a performance test and making
the necessary adjustments.   For this reason, incinerators operating at the
temperatures  and residence times expressed by the commenter  in conditions  (b)
and (c) are not exempt from  the performance test requirements.
     The  EPA  has determined  that steam generating units with heat  input
capacities of 44 MW  (150 million Btu/hr) or greater  consistently achieve
proper mixing.  These units  have conditions of temperature and residence time
that generally are well in excess of the most severe conditions necessary  to
achieve 98 percent efficiency.   It is to the economic advantage of  the owner
or operator to design and operate such devices with  very  good mixing  of gases
to maximize the combustion efficiency and subsequent steam generation  rate.
Thus,  these steam generating units are exempt from the performance  test
requirement of the  standards.
                                     2-39

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     2.7.3 COMMENT;  One commenter (D-ll) suggested that EPA provide for
alternative methods of demonstrating compliance when air oxidation process
emissions are combined with other emission sources within the plant.  For
example, vent gases from air oxidation processes may be incinerated in
wood-fired boilers.  Since wood-fired boilers inherently generate VOC
emissions, demonstration of compliance with the proposed regulation may be
difficult.

     RESPONSE:  The General Provisions, 40 CFR 60.8, state that the
Administrator may approve the use of "an alternative method [of demonstrating
compliance] the results of which [s]he has determined to be adequate for
indicating whether a specific source is in compliance" with -a standard.  This
is applicable to all NSPS and need not be specified in the regulation.
     When air oxidation streams are combined with nonair oxidation offgas
streams within the plant, compliance of the combined stream may be demon-  •
strated using Reference Method 18 or an alternative method approved for the
particular facility by the Administrator.  The EPA has determined that if
compliance is demonstrated with the combined stream, compliance would also be
achieved when routing the air oxidation stream alone.
     In the commenter's example wherein a wood-fired boiler is used to
incinerate air oxidation vent gases, VOC will be generated by the combustion
device itself.  In this case, the total VOC reduction would still have to be
98 percent.  If the VOC generated by the wood-fired boiler prevents this, the
affected facility will not be considered in compliance with the standards.

     2.7.4 COMMENT:  One commenter (D-2) suggested that EPA define the term
"continuous" from Section 60.611 to represent a record with data sampled and
recorded at a frequency of at least 1 percent of the compliance period.  This
commenter stated that such a definition would enable EPA to achieve its
purposes while still allowing industry to use a documentation system
compatible with existing computer-assisted control systems.  This commenter
said that existing monitors record at a frequency varying from a few seconds
to several minutes.  The commentej also stated that a separate analog system
with a continuous recorder Tvould be difficult to implement.
                                    2-40

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     RESPONSE;  The EPA has agreed to clarify the meaning of "continuous" in
Section 60.611 as follows:  "'Continuous recorder' means a data recording
device recording an instantaneous data value at least once every 15 minutes."
This definition will enable industry to use existing computerized data control
systems attached to a measurement device.  Furthermore, this time interval has
been found to be an adequate time period for providing EPA with sufficient
data to ensure proper operation and maintenance of VOC control equipment.

     2.7.5 COMMENT:  One commenter (D-ll) stated that alternative measurement
methods should be considered for demonstrating compliance with the proposed
standards.  This commenter stated that under the proposed regulation,
Method 18 is required for demonstrating compliance and would necessitate that
certain plants in the industry develop an analytical procedure with sufficient
sensitivity to demonstrate compliance with the standards.  This commenter
indicated that other methods with sufficient sensitivity to determine
compliance are already available.

     RESPONSE;  As with comment 2.7.3, the General Provisions (40 CFR 60.8)
permit the Administrator to approve alternative means of demonstrating
compliance on a case-by-case basis, providing the proposed alternative method
is adequate for this purpose, or to waive compliance demonstration
requirements if the owner or operator has already adequately demonstrated
compliance.  Since the General provisions are applicable to all NSPS,
provisions for approval of test methods need not be specifically stated in the
regulation.

     2.7.6 COMMENT:  One commenter (D-4) stated that the 98 percent VOC
destruction efficiency required for thermal incinerators should be verified by
analytical measurements and not just by operating temperature.  The commenter
stated that this would provide a more accurate performance assessment and,
thus, enable both users and governmental monitoring authorities to judge the
relative merits of various control equipment designs against a consistent
standard.
                                     2-41

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     RESPONSE;  The standards already require an initial  performance test to
determine mass destruction efficiency using sampling and analytical methods,
as suggested by the commenter.  During the initial  performance test used to
demonstrate that the thermal incinerator is achieving 98 weight-percent
reduction of VOC emissions, the temperature is measured continuously.  If the
efficiency is verified, then the temperature measured is used as a baseline
by which the owner or operator can determine proper operation and maintenance
of the control equipment, and it indicates that conditions have remained
unchanged from the initial performance test conditions.  Deviations from this
"optimal" temperature can indicate significant decreases in control device
efficiency.  Because of this, once initial performance testing has been
performed and a temperature baseline has been set, temperature monitoring
alone is sufficient to demonstrate proper operation and maintenance.

     2.7.7 COMMENT:  One commenter (D-3) stated that the sampling  site for
TRE measurement should be located after a catalytic oxidizer when  such a unit
is employed as an  integral part of the system.  The commenter also pointed  to
an apparent inconsistency  in  the treatment of catalytic oxidation  between the
BID and the proposed regulation.  The commenter indicated that although the
in-process catalytic oxidizer is properly discussed in the BID, no rationale
is presented  in either the  BID or the preamble to the proposed regulation for
the exclusion.

     RESPONSE:  The CAA  authorizes the Agency to minimize the emissions at
new, modified, and reconstructed sources by  application of BDT.  The
injunction does not constrain the Agency from regulating points that  are an
integral part of  the process  (i.e.,  points other than the final emission vent
to'the  atmosphere) for a facility within a particular  industry.  Certain
integral process  points  may be regulated when these points include devices
that are normally used as  control units.  The catalytic oxidation  unit to
which the  commenter refers is employed  as  an essential element  in  an  inte-
grated  air compression/energy recovery  system.  Although the  unit  is  not used
as a terminal  control  device, itjs  an  efficient VOC destruction device  and,
as such, performs the  function of a  control  device.  For the  air oxidation
                                     2-42

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NSPS, the use of a catalytic oxidizer is not excluded and the unit may be
employed as a control  device when compliance testing shows a 98 percent VOC
destruction efficiency or 20 ppmv VOC emission limit (i.e., the control level
associated with BDT, thermal incineration).  Based upon available data, the
Agency believes that catalytic oxidation units can achieve a 98 percent
destruction efficiency or 20 ppmv emission limit in cases where they are
applicable.  The Agency has determined that for streams with a TRE index
below 1.0 (i.e., measured after the final recovery device but prior to a
control device), the cost of control would be reasonable.  Thus, the Agency
believes it is proper to require the TRE measurement before the inlet to the
catalytic oxidation unit.

2.8  EXEMPTIONS

     2.8.1 COMMENT:  One commenter  (D-5) stated that the regulation should
provide for an exemption in the case of organic pollutants which have been
demonstrated to possess a negligible ozone-producing capability (i.e., are
not  photochemically reactive).  This commenter indicated that no
consideration has been given to the ozone-producing potential of individual
VOC  species.

     RESPONSE:  The air oxidation NSPS are  intended to cover air oxidation
facilities that emit VOC (i.e., compounds which participate in  atmospheric
photochemical reactions to  produce  ozone).  Since compounds with negligible
photochemical reactivity do not contribute  appreciably to  the formation  of
ozone,  the Agency believes  that  it  is appropriate to exclude these compounds
in determining  a TRE  index.   Facilities  should measure only VOC; rather  than
TOC, when  quantifying  the  hourly  emissions  rate for  input  into  the TRE
equation.  For  example,  if the vent stream of a facility contains 90  percent
negligibly reactive organic compounds and  10  percent reactive organic com-
pounds,  only 10 percent  of the organic  compounds  emitted from that facility
would  be considered for  calculating a TRE  index.  Although subtraction of
                                     2-43

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negligibly reactive compounds is permitted, it is expected that no significant
change in national impacts will occur since very few air oxidation vent
streams contain these compounds.
     To allow for the subtraction of compounds with negligible photochemical
reactivity in calculating a TRE index, several changes have been made in the
regulation.  The definition of TOC's in Section 60.611 has been amended as
follows:  "'TOC's means those compounds .... in Section 60.614.  For the
purposes of measuring molar composition as required in Section
60.614(d)(2)(i), hourly emissions rate as required in Section 60.614(d)(5) and
60.614(e), and TOC concentration as required in Section 60.615(b)(4) and
60.615(g)(4), those compounds that the Administrator has determined do not
contribute appreciably to the formation of ozone are to be excluded.  The
compounds to be excluded are identified in EPA statements on ozone abatement
policy for SIP revisions (42 FR 35314; 44 FR 32042; 45 FR 32424;
45 FR 48942)."  These Federal Register notices are included in Appendix C of
this document.
     Even though subtraction of compounds with negligible photochemical
reactivity is permitted in determining a TRE index value, the 98 weight-
percent reduction requirement and 20 ppmv emission limits in the standards are
based on the control of TOC's, minus methane and ethane.  This is because the
Agency evaluated BDT based upon the control of TOC's, not just reactive
compounds.  The Agency derived the weight percent emission reduction
requirement and emission limit for air oxidation processes from data gathered
using test procedures that measured TOC's, minus methane and ethane.  No other
VOC species, including compounds with negligible photochemical reactivity,
were subtracted in evaluating BDT.  Thus, to reflect accurately the
performance of the technologies selected as BDT and to make the emission
limits consistent with the data and test methods from which they were derived,
the Agency will continue to express the emission limits in terms of TOC's,
minus methane and ethane.
                                     2-44.

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2.9  GENERAL

     2.9.1 COMMENT:  One commenter (D-6) requested better documentation of
contacts between EPA and the Office of Management and Budget (OMB),
especially in regard to the cost-effectiveness cutoff used in the proposed
standards.  To substantiate this request, the commenter cited Sierra Club v.
Costle. 657 F.2d 298 (D.C. Cir. 1981), in which the court accepted the
practice of reducing oral communications to memoranda and inserting them in
the docket.  This commenter also cited the CAA Section 307(d)(4)(B)(ii),
which requires written communications to be placed in the public docket.
     RESPONSE:  All correspondence between EPA and OMB directly related to
the proposed NSPS for SOCMI air oxidation processes is contained in Docket
No. A-81-22, which is available for public inspection.  The correspondence
can be found under Docket Item Numbers II-C-24, II-F-1, and II-F-2.  In
addition, EPA has identified three pieces of correspondence between the
Agency and OMB which discussed the development of a cost-effectiveness cutoff
as part of the preparation of the CTG for air oxidation processes.  These
letters have been forwarded to the commenter and entered into Docket No.
A-81-22, Category IV-C.
     The policy of how any communication between EPA and another Federal
agency should be treated by EPA has been clearly described in a letter from
the Administrator to the commenter's organization (Docket Item No. IV-C-3).
                                    2-45

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APPENDIX A:  TRE EQUATION AND COEFFICIENT DEVELOPMENT
                     FOR THERMAL INCINERATORS

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            APPENDIX A:  TRE EQUATION AND COEFFICIENT DEVELOPMENT
                                 FOR THERMAL INCINERATORS

A.I  INTRODUCTION
     This appendix describes the development of the TRE index equations used
in the proposed standards for air oxidation processes.  These equations can
be used to directly calculate the TRE index based on the vent stream flowrate
(scm/min), heating value (MJ/scm), and VOC emission rate (kg/hr).

A. 2  INCINERATOR TRE INDEX EQUATION
     This section presents the method used to develop the incinerator TRE
index equation and an  example calculation of the  incinerator TRE  index.

A. 2.1   Incinerator TRE Index Equation Development
     The  incinerator TRE index equation  was developed  in the following
manner.   First,  an equation for  total annual ized  cost was determined  by
combining the  equations for each component  of  the annual ized costs.   The
equations for  each  annual ized cost  component are  shown  in Docket  Item
No.  IV-B-14  and  include annual ized  capital  costs, supplemental  gas costs,
labor  costs, electricity costs,  quench water costs,  scrubber water costs,
neutralization costs,  and  heat  recovery  credits.
      The equation for  total  annual ized costs developed from the equations  for
each annual ized cost component  (Docket  Item No.  IV-B-14)  was  divided by the
 amount of VOC  removed  and  the  reference  cost  effectiveness  of $l,900/Mg of
VOC removed to generate the general TRE  index  equation.  Collecting like
 terms results  in an equation with the following form:
TRE
          s
       f (Y)0'5]
 where for a vent stream flowrate (scm/min) at a standard temperature of 20 C
 is greater than or equal to 14.2 scm/min:
                                      A-l

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     TRE  = TRE index value.

      Q   - Vent stream flowrate (scm/min),  at a standard temperature of
       s    20°C.

       HT = Vent stream net heating value (MJ/scm),  where the net enthalpy
            per mole of vent stream is based on combustion at 25 C and
            760 mm Hg, but the standard temperature  for determining the
            volume corresponding to one mole is 20 C,  as in the definition
            of Q$.

     ETQC - Hourly emissions of TOC's reported in kg/hr measured at full
            operating flowrate.

       Y  = Q  for all vent stream categories listed in Table A-l except for
        s   Citegory E vent streams where YS - (Q$)(HT)/3.6.

where for a vent stream flowrate (scm/min) at a standard temperature of 20°C

that is less than 14.2 scm/min:


     TRE - TRE index value.

      Q  = 14.2  scm/min

      HT= (FLOW)(HVAL)/14.2

where:

     FLOW = Vent stream flowrate (scm/min), at a temperature of  20°C.

     Hy.. = Vent stream net heating value (MJ/scm),  where the net enthalpy
            per  mole  of vent stream is based on combustion  at 25 C and
            760  mm Hg, but the  standard temperature for determining  the
            volume corresponding to one mole  is 20 C, as  in  the  definition
            of Qs.

     ETnr = Hourly emissions of TOC's  reported  in kg/hr measured at  full
            operating flowrate.

        Y  » Q   for all vent stream categories  listed  in Table A-l except  for
         s   dtegory  E vent streams where Y$  -  (Q$)(HT)/3.6.

     The  coefficients a through f  are  functions of  incinerator  design

 parameters, such as  temperature, residence  time,  supplemental  fuel
 requirements,  etc.   As discussed  in  Chapter 8 of  the  Air  Oxidation  Processes
                                      A-2

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TABLE A-l.  AIR OXIDATION NSPS TRE COEFFICIENTS FOR VENT STREAMS CONTROLLED BY AN INCINERATOR
DESIGN CATEGORY Al. FOR HALOGENATED PROCESS VENT STREAMS, IF
Q - Vent Stream Flowrate (scm/mln) »
14.2 < Q < 18.8
18.8 < Q* < 699
699 < Q* < 1*00
1400 < Q* < 2100
2100 < Q* < 2800
2800 < Q* < 3500
19.18370
20.00563
39.87022
59.73481
79.59941
99.46400
DESIGN CATEGORY A2. FOR HALOGENATED PROCESS VENT STREAMS, IF
Q - Vent Stream Flovrate (san/min) a
14.2 < Q < 18.8
18.8 < Q* < 699
699 < Q* < 1400
1400 < Q* < 2100
2100 < Q* < 2800
2800 < Q* < 3500
DESIGN CATEGORY B. FOR NONBALOGEKATED PROCESS
Q - Vent Stream Flowrate (scm/min)
14.2 < Q < 1340
1340 < Q* < 2690
2690 < Q* < 4040
DESIGN CATEGORY C. FOR NONHALOGENATED PROCESS
Q - Vent Stream Flovrate (scm/mln)
14.2 < Q < 1340
1340 < Q* < 2690
2690 < Q* < 4040
DESIGN CATEGORY D. FOR NONHALOCENATED PROCESS
Q - Vent Stream Flowrate (scm/mln)
14.2 < Q < 1180
1180 
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proposal BID, there are six different design categories of incinerators.
Table A-2 presents the updated heating values and flowrate intervals
associated with each category.  Substituting the design values into the
general equation allows values for coefficients a through f to be derived for
each design category.  This derivation is included in Docket Item
No.  IV-B-14.
     The results of  this derivation  are summarized in Table A-l.  As shown,
the  coefficients are divided  into  six  incinerator design  categories.   Under
each design  category listed in Table A-l, there  are  several intervals  of  vent
stream flowrate.   Each flowrate  interval  is associated  with a  different  set
of coefficients.   The  first flowrate interval  in each  design  category  applies
to vent streams with a flowrate  corresponding  to the smallest  control
 equipment system easily available without special  custom design.
      The remaining flowrate intervals in each  design category apply to vent
 streams which would be expected to use two, three,  four, or five sets of
 control equipment,  respectively.  These flowrate intervals are distinguished
 from  one another because of limits  to prefabricated equipment sizes.

 A.2.2 c^pio ra1r.nat1o- •»* »  TnHnerator-ha
        for  a  Facility
       This  section presents an example of use  of the TRE index equation.   The
  example  reactor process vent stream has  the following characterises:

       1.    q     * 284 scm/min
       2.    HT    =0.37 MJ/scm
       3.   ETQC  =76.1 kg/hr.
       4.   Y     =284 scm/min.
        5.   No  halogenated compounds in the  vent stream.
        Based on the  stream heating value  of 0.37 MJ/scm,  Category B  is the
   applicable incinerator  design  category  for this stream.  The flowrat,,  «-.-
   2   scm/min,  and therefore  the coefficients  for the  first flowrate interval
   under Category B are used.   The coefficients for  Category B, flow interval
   are:
                                        A-4

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      TABLE A-2.   MAXIMUM VENT STREAM FLOWRATES  AND  NET HEATING VALUE
                  CHARACTERISTICS FOR EACH DESIGN CATEGORY
Minimum Net
Heating Value
Category (MJ/scm)*
Al 0
A2 3.5
B 0
C 0.48
D 1.9
E 3.6
Maximum Net
Heating Value
(MJ/scm)*
3.5
-
0.48
1.9
3.6
-
Maximum Process Vent
Stream Flowrate at
Incinerator Inlet
(103 scm/min)
0.70
0.70
1.34
1.34
1.18
1.18
These values are based on process vent stream conditions.
                                   A-5

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     a = 8.54
     b = 0.106
     c = 0.090
     d = -0.171
     e =  0
     f =  0.010

The TRE equation is:
                     0.88 .  _/n \  .  jin \/u \  .  _ / n  0.88 \ / u  0.881
TRE = E    [a + b(Qsr°° + c(Q$) + d(Qs)(HT)  + e(Q$
      f (Qs)0-5]
     TRE = (.013)[8.54 + 0.106 (284)0'88 + (0.090)(284)"°-171
           (284) (.37) + 0 + (0.010)(284)0'5]
     TRE = 0.111 + 0.199 + 0.332 - 0.236 + 0 + 0.002
     TRE = 0.408
Since the calculated TRE index value of 0.408 is less than the cutoff value
of 1.0, this facility would be required to reduce VOC emissions by 98 weight-
percent or to 20 ppmv because the cost of incineration is considered to be
reasonable.  Because the TRE index is a ratio of two cost-effectiveness
values, it is possible to calculate cost effectiveness for controlling any
vent stream given its TRE index value.  The TRE index value of the facility
is multiplied by the reference cost effectiveness $l,900/Mg as follows:

     TRE = 0.408
     Reference cost effectiveness » $l,900/Mg
     Cost effectiveness for example stream - (0.408) (1,900) = $775/Mg of
      VOC removed
                                      A-6

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APPENDIX B:  CAPITAL COST COEFFICIENTS

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                    APPENDIX B:   CAPITAL  COST COEFFICIENTS
     One  comment  received  after  proposal of  the  standards noted  a  discrepancy
concerning graphs  in  the proposal BID showing total  installed  capital  costs
The data  presented  in these graphs were  used to  develop coefficients  for  the
capital cost equation shown in Table 8-5 (proposal BID).  As indicated  in the
response  to public  comments, the Agency has modified the  cost  equations to
correct the small discrepancy noted by the commenter.  A  corrected copy of
Table 8-5, which presents the capital  cost coefficients used in the cost
equation,  is presented in Table B-l.
                                   B-l

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        TABLE B-l.  TOTAL INSTALLED CAPITAL COST EQUATIONS AS A FUNCTION OF OFFGAS FLOWRATE
                                                                                           ,29,30


Category
Al
A2
B
C
D
b
E
Maximum
Flowrate
Per Unit
(Thousand)
(scm/inin)
0.74
0.79
1.52
1.52
1.34

1.34
Fabricated
Equipment
Cost
Escalation
Factor
.900
.900
.900
.900
.900

.900
Design
Vent
Size
Factor
.95
.95
.95
.95
.95

.95


Cl
803.11
786.61
259.89
297.99
236.35

236.35


C2
12.83*
12.44*
4.91
2.84
3.23

3.23


C3
0.88
0.88
0.88
0.88
0.88

0.88
Total Installed Capital Cost ($1,000) - (* of Units)  x (Escalation Factor)  x (Cl + C2 x
((Flowrate (son) divided by Design Vent Size Factor)C3))°
            min

 Flowrate Correction Factor of 1.12 - (1.14)"   Incorporated into  Coefficient C2.

 Dilution Flowrate is Used in Capital Cost Equation.
 Dilution Flowrate - (Design Flowrate) x (Original Heating Value)  divided by (3.6 MJ/scm)

 Flowrate per equipment unit.
                                               B-2

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APPENDIX C:  FEDERAL REGISTER NOTICES OF
  ORGANIC COMPOUNDS DETERMINED TO HAVE
   NEGLIGIBLE PHOTOCHEMICAL REACTIVITY

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              APPENDIX C:  FEDERAL REGISTER NOTICES OF ORGANIC
                   COMPOUNDS DETERMINED TO HAVE NEGLIGIBLE
                          PHOTOCHEMICAL REACTIVITY
INTRODUCTION
     As indicated by the Federal Register notices included in this appendix,
the following chemicals have been determined to be negligibly photochemically
reactive compounds: methane; ethane; 1,1,1-trichloroethane; methylene chlo-
ride; trichlorofluoromethane; dichlorodifluoromethane; chlorodifluoromethane;
trifluoromethane; trichlorotrifluoroethane; dichlorotetrafluoroethane; and
chloropentaf1uoroethane.
                                    C-l

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    35314

       ENVIRONMENTAL  PROTECTION
                  AGENCY
                 l«U.73S-»|

                AIM QUALITY	

                      on Control of VetetHe
      The purpose of this notice to to rec-
    ommend a policy for States to follow on
    thu i*nntml nf yqlifflq ^ry»Tri>i """ttpflrouli
    (VOC). which art a constituent in the
    formation of  photochemical  "^11"*^
    (smog) . ibis notice doee not place any
   requirement! on States; State implemen-
    tation Plan (SIP) provisions which offer
    reasonable altemattres to this policy will
    be approvable. However, this policy will
    be followed by EPA whenever  it is re-
   quired to draft State  Implementation
   Flans for the control- of photochemical
     Photochemical  ozldants result from.
   sunlight acting on volatile organic com-
   pounds (TOO  and oxides of nitrogen.
   Some VOC. by their nature, start to form
   oxidant after only a chart period of ir-
   radiation-la the atmosphere. Other VOC
   may undergo irradiation for a longer
   period- before  they yield, measurable
	Jnlts (uidance.to States tar the prep-
   aration, adoption, snd submittal of State'
   Implementation Plans published in 1971.
   the Environmental Protection Agency
   empnastonrt reduction of total organic
   compound «mt««iq««T  rather than sub-
   stitution. (See 40 CFR Part'SI, Appendix
   BJ However, in Appendix B, EPA stated
•   that substitution of one compound for
..  mother might b*.useful where it would
   result to  a clearly evident decrease In
   reactivity and thus tend to reduce photo-
   chemical   ozidant  formation.  Subse-
   quently, many State.  Implementation
   Plans  were promulgated  with solvent
   substitution provisions  similar to Rule
   M of the LOB Angeles County Air Pollu-
   tion Control District. These regulations
   allowed exemptions for many organic
   solvents which have now been shown
   to  generate significant photochemical
   oxidant.
    On January 29, 1976, EPA  published
  Its "Policy Statement on Use of the Cen-
  eept of Photochemical Reactivity of Or-
 . ganlc Compounds in State Implementa-
-. tton Plans for Oxidant Control.'' The
  notice of availability  of this document
  appeared  to the Fnnuu  RiCBzn  on
  February S. 197« (41 FR 3330).
    The 1978 policy statement emphasized
  that the reactivity concept was useful
 ..at an interim measure only, and would
  not be considered a reduction in organic
  emissions for purposes of estimating at-
  tainment  of the ambient  air quality
  standard for  oxldants.  The document
  also Included the following statement:
    Although the substitution portions of Rule
  ee and similar  rules  repment a workable
  uut acceptable program at th* present time.
  better (abnttntten regulation! can be de-
  veloped, baeed oa current  knowledge of re-
               NOTtCE*

 activity and industrial  eapaaflltr. XPA m
 eaUBbanaoB with State and iadotry repre-
 ••MUM «oi formulate  IB  urc an la-
 prond rule ror national u*e.
             -SUMMARY		
   Analysis of available data and infor-
 mation show that very few volatile or-
 ganic compounds are of such low photo-
 chemical reactivity that they  can be
 ignored  in oxidant control programs.
 For this reason,  EPA's  «^rnr»«n^ttt
 PoUcy reiterates  the need for positive
 reduction techniques (such as the reduc-
 tion of volatile organic compounds in
 surface coatings, process, changes, and
 the  use  of  control  equipment)  rather
 than the substitution of compounds of •
 low  (slow)  reactivity  in the place of
 more highly (fast) reactive compounds.
 There are three reasons for  this. First.
 many of the VOC that previously have
 been-designated as having low reactivity-
 are  now  known  to be  moderately or
highly reactive in urban atmosphere!
Second, even compounds, that an pres-
ently known to have low reactivity can
 form appreciable  amounts  of oxidant-
under  mulUday «*»gn«Ufrci  i*«idtq.rM
such as occur during summer in many-
areas. Third, some compounds  of low

                      '
                                         JrYeon 114. and Freon 115. which are cur-
                                         reatly used as aerosol propellants. The.-
                                         *»aqr to planning to Investigate control
                                         •nOrns and substitutes for nonpropel-
                                        - lans-usee under TBCA. as announced oa •
                                         May 13. Methyl chloroform is not a fully
                                         halogenated chloronuoroalkaae. Rather
                                         It is among the chlorine-containing com-
                                         pounds for which the Agency has not
                                         completed its analysis: EPA has not yet
                                         concluded whether it is or is not a threat
                                         to the stratospheric ozone. Therefore. It*
                                         has been placed on this list as an accept-
                                         able exempt compound. As new informa--'
                                         Hon .becomes available on these com-.
                                        .pounds. EPA will reconsider  the recom-
                                         • 15*7ai£t5!Lors!*nte compounds listed*
                                         in Table 2. while more photochemically "
                                         reactive than, those in Table 1.  never-
                                         thelesa do not contribute large quantities;
                                         of oxidant under many atmospheric coo.-.
                                                         Orponic. Compound*
                                                   fhotaeatmleat AeacttMty nut-'
                                               Impt
                                                             Plant
   O2 the small'number of VOC which
•have only negligible- photochemical re-
 activity, several. (benzene, .aeetonlteile.
 chloroform, carbon tetrachlortde. ethyl-
 ene dlchlortde. ethylene dibromide. and
 methylene chloride) have been identified
 or implicated as being carcinogenic, mu-
 tagenlc. or teratogenic. An' additional
 compound, benzaldehyde. while produc-
 ing  no appreciable ozone, nevertheless,
 forms a strong eye irritant under Irradia-
 tion. In view of these circumstances, it
 would be Inappropriate for EPA to en-
 courage or support increased utilization
 of these compounds. Therefore, they are
 not  recommended  for exclusion from
 control. Only the four compounds listed
 In Table 1 are recommended for exclu-
 sion from SIP regulations and. therefore.
 it is not necessary that they be inven-
toried  or controlled. In determining re-
ductions  required'  to  meet  oxidant
NAAQS. these VOC  should  not be In-
cluded in the base line nor should reduc-
tions in their emission be credited toward
achievement of the HAAQS.
 '.It is  recognized that the two halo-"
genated compounds  listed  In  Table  I
 (methyl chloroform and Freon 113) may
cause deterioration of the earth's ultra-
violet radiation shield  since they are
nearly unreactive in  the lower atmos-
phere and all contain appreciable frae-'
tlons of  chlorine. The   Agency  has
reached conclusions on tht effects of only
the  fully  halogenated  chlorofluoroal-
kanes. The Agency on May 13. 1977 (43
FR 24542), proposed rules  under  the
Toxic Substances Control Act (TSCA) to
prohibit  the  nonessentlal  use of fully
halogenated chlorofluoroalkanes as aero-
sol propellants. The restrictions were ap-
plied to all members  of this *i«««, in-
cluding Freon  113. since they are poten-
tial substitutes for Freon 11.. Freon 12.
                                       :UJ-THehloroethane (Methyl Chloroform^.''
                                       Wchlemrlfinoroethaae (Freon 113)'

                                      •• -xTfc«c compound* have  beea Implicate*^
                                      - ee haTtng-deleterloue effect* on atratoiphtrlet
                                      -•ennBd. therefore, may be subject to ~ •-
                                      ..tnrecoatrau.  ..	„
                                            .-.t  organic Compound,
                                        tan fhotoehtmiett Rtactiaity        "
                                       Methyl Ethyl Ketone
                                       Methanol  '..
                                       Xnptopaaoi
                                       Methyl Benaoate    *  '
                                       Tertiary Alley! Alcohols
                                       Methyl Aoetaie   ..
                                       Phenyl Acetate
                                       Ethyl Amtna*   •'•  -
                                       Acetylene
                                       1C. N-dlaet&yl formaailde

                                        Only during multlday stagnations dol
                                       Table  2 VOC yield significant oxtdanta,'
                                       Tlieiefuie. if resources are limited or : "
                                       the sources  are located in areas wbei..
                                       prolonged atmospheric  stagnations are*]
                                      •uncommon, priority should be given  ' "
                                       conteofllng more reactive VOC first u—
                                       Table 2 organics later. Table 2 VOC art}
                                       to be Included in base line emission in-".,
                                      ^eateries and reductions hi them will b«r>|
                                      credited  toward  achievement  of  the"
                                      MAAQa  Reasonably  available  control
                                      technology should be  applied to signlil--!
                                      cant sources of Table 2 VOC where news- - -,
                                      sary to attain the NAAQS  for oxldants. «i
                                      New sources of these compounds will also ^
                                      be subject to new source renew require--.?
                                      ments.                             ••"*'•§
                                       • Perchloroethylene. the principal sola?,
                                      vent employed in the dry cleaning indis-^ I
                                      try. is also of low reactivity, comparable '
                                      to VOC listed in Table 2. It was  not la-
                                      eluded to Table 2 because of reported ad- •
                                      verse health effects. Uses, environmental • ,
                                      distribution,  and effects of  perchloro-,-.l
                                      ethylene currently are being studied is-..: I
                                      tensively by occupational health author-  '
                                      ethylene currently are being studied in-
                                      vestigations may have major impact aa
                                   FtDERAl ttGISTH, VOl.  «, NO. 131—WIOAY, JOIY I, l»7f   , j»^  3sJ» V - J"J J'fc.


                                                          C-2

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 ttuiustrlal users, in designing control reg-.
          for perchloroethyleni
  particularly dry cleaners, eonsideratioa
  should be given to these findings as well
  as miliBlfy lequtieuients and the.eost of
  applying controls. Available control tech-
  nology Is highly cost effective for large
  perfshloroethyiene dry cleaning* opera-
  tions*. Howeveri  for coin-operated and,

  would  represent a  heavy  "economic
  burden.
    As part of its continuing program, EPA
  wfll review new information relative to '
                                                       NOTICES

                                           Investigation showed that:
                                           1. Solvent gnhst^tiffn tisagfl on Bute
          or deletions win be T*JIF to *****
 ll*t» of VOC in. Ttbeli 1 and 3.  .
                                        68 hat been dlncUonaOy correct
                                        aggrente and probably effects some re-
                                        ductions la peak ozldant  level*. Bow*
                                        ever, because of the relatively Ugh re-
                                        aetMty of meet of tne substituted aol-
                                        Tents. +J?ft ^^'MftlflTi Is small compared, to
                                        that which ^*TI be f^^^nnUffrftl with
                                        positive rffiinr***?!!  tftfnrrtipiflB Bevisioa
                                        of Rale S8 consistent with current knowl-
                                        edge at reactivity would, flMflTi***t the
                                        Solvent substitution option, for most
                                        sources, In. which substitution la new  em-
                                        ployed. Many of toe  organic solvent*
                                        which  have been categorized, a*  having.
                                                     *1^ reactivl^ are. ln> fact*
   y^i^sft «Eir poUutioB ffiuti'ni
                               of VOC
 in t&tf Olittod
 gate «t_cf tee I*m Angetoi Ownty Atr
 I^oOottoB'  QoirtFM Dtftrtcc.  i&msBttf
 Begatation 443 of to* Southern Cantor-
 ate Air PoOutton Control Dlsaictt. Bate
 «6 and similar regulations, incorporate
 two basic  strategies to reduce ambient
     erately or. frfgfrfy reactive* +*»T yield.
 Kiytiifli»aTifc oxldaat when, subjected, to
 irradiation. In. smog chambers. designed to
 simulate, the urban* atmosphere.
   2. A  few VOC yield, only negligible
 ozone) whea <»*«*u*t*rf *** a
 under beta urban, and. ru
                                                                 al conditions.
                                                              to. fnfa
                                        oth

                          '
tton. absorption, and the use' of low-sol-
veot coattags an acknowledged means of
reducing ambient oxidant levels: they
should be retained m future VOC control
programs. la contrast, the utfltty of sol-
vent substitution strategies has  been
questioned as more information on pho-
to chemical reactivity ha* emerged.
  EPA  acknowledged the
of solvent substitution
                      based on Bute 66
 reactivity criteria la a 1978 policy state-
 meat (41 PR 53*0). Finding* were cited
 which  Indicated that almost  aB VOC
 eventually react m the atmosphere to
 form some oxidant. Concurrently..EPA
 initiated an investigation to consider im-
 plications of revising the solvent substi-
 tution aspects of Bate 66. Three separate
 forms were conducted with repiBssntm
 «*•*••• of State aad local  air pollution
 control agencies,  university  professors.
 and  industrial  representatives  with
 knowledge and expertise ia-the fields of
 Msaoapherte chemistry aad industrial
snlveat applications, to addition,  nu-
merous dteraattons were held with ac-
knowledged experts la the Held. Topics
of particular concern were:
           Bole M nttw.tta.leB, criteria
      b» rertaed oonnitent wtttt available
         data and yM be compaable with
          pmcmti and wltfe product  re-

  """"•hetner torn* compound* am or «ufl-
H "<.tly low ""••"Bvlty taat tney-are not oxl-
     •"reeunon and can be exempted from
       under state Implementation Plan*.
      teer tne imposition of naettvtty  re-
ratettoo* in addition to  porttln emlrtoa
f*«ueton«  wm delay to* development or
               or promiatag
             • uee ot
                   and ethane, a. group
                   fans, and three other
                    bensaldehyde... and
 afttnnltmn  can ba- so-classified. Thaw
 compounds react* vsry slowly  yielding
 llttla osan* during, .the, first few days.
 (YlUlM! 'IIS, **<*<*• f»l*m»m ffft tfl^ ^frfywi'V^'^
 Available data, suggest that none of the.
 listed compounds. eoatrOmtst significant.
 f.»
-------
  35316

 spread substitution of methyl chloroform
  (U4 trtehloroethanel for the  photo-
  Fhemlcally reactive decreasing  solvent
 trJchloroethylene. Socb substitution un-
 der Bole «« generation regulations has
 already influenced industrial degreeslng
  operations to the extent that  methyl
 chloroform  production  has  surpassed
 that of tnchloroethylene In the United
  States. Any regulation in the area .win
 have a marked effect on the production
 and atmospheric •mln**""" -of both sol-
  vents. Endorsing methyl chloroform sub-
  stitution would Increase emissions, par-
  ticularly in industrial States that have-
  not, heretofore. Implemented Bute «8. On
  the other hand, disallowing methyl cnlo-
  roform as a substitute or banning it alto-
 gether would significantly increase amis-''
 sions  of triehloroethylene even if de-
  greasers were controlled to the limits of
 available' technology. Presently.- teeh-
 •nology is only able to reduce emissions by
 approximately SO percent. In metropoli-
 tan areas  which- have  already Imple-
  mented Rule 88. a return to triehloro-
 ethylene would have  an advene effect
^*oo ambient oxldant Icvele. fit ad*flmfl»i to
;.bemg highly reactive, triehloroethylene
   Alternative* to the abi
 ^would be (l)^devetopment and appllca-
 .tton of h*f/***y efficient degreaser control
-•.systems'end -(2) 'replacement with an
               NOTICES

 ivttmntm^m.t^ solvent which is neither re*
 •CUT* nor detrimental, to toe upper aw
 mosphere.  Major  revision*  would  be
 needed to degreaser "V^gr"* to improve
 vapor capture above  toe current best
 level. Anticipated design ******tft could
 add materiallr to degreaser costs. No. al-
 ternative solvent is  clearly  acceptable
 from ^f standpoints of photodi*1"1^*!
 oxidant and stratospherie ozone deple-
 tion. Neither  methylene  chloride nor
 trtchlorotrtfluoroetaane are reactive, but,
 like methyl chloroform, are suspected of *
 causing damage  to  the  stratospheric
 none layer. In addition, methylene chlo-
 ride 4» a  suspect mutagen. Perchloro-
 ethylene. the principal dry. cleaning sol-
Tent, does not present a hazard to the
 stratosphere bat has been implicated as.
-being svcarcinogen and also reacts slowly
 in the atmosphere to form oxidant.
   7.- Organic solvents of low or negligible
 p)^t««»hyn<««i,- • reactivity have  only

 chlorinated organics that find principal
 applications as cleaners for metal* and
 fabrics. A few nonhalogenated VOC such
 as acetone, methyl  ethyl ketone. and'
 isopropanol are of low reactivity but
 these, can't possibly satisfy afl the myriad
 needs of the paint, plastics; pharmaceu-
 tical,  or many other-industries.. •While
 users of reactive VOC usually can employ
' effective control equipment to recover or
                                                                               destroy VOC emissions, they seldom have
                                                                               the option of applying reactivity con-
                                                                               siderations In choosing solvents. Applying
                                                                               reactivity restrictions to the surface coat-
                                                                               ing industry would be especially disad-
                                                                               vantageous since it would greatly inhibit
                                                                               the development of low-solvent coatings;
                                                                               -essentially a*i of  *h* organic solvents
                                                                               wsffd to constitute high-solids coatings
                                                                               and water-borne coatings  are. in fact,.
                                                                               highly reactive.
                                                                                 S. It Is recognized that smog chamber'
                                                                               studies conducted to date are Incomplete
                                                                               because many organic compounds have
                                                                               not been examined and it ***** been lm-'
                                                                               possible to duplicate all atmospheric sit-;
                                                                               nations.  Tor trample, there baa been.
                                                                               ntily Htjiiffljf ygMtiitwfchm of OXidftnt fOT-.!
                                                                               matlon under relatively  high ratios  of.*
                                                                               VOC to NO, (30:1 and greater). compar-r
                                                                                         tre^ reactivity necessarily
                                                                               to be open to revision as new information "
                                                                               la developed which may show specific
                                                                               organic compounds to be more or less.
                                                                               DbotocnemlcaUy. reactive ^*MI indicated.'
                                                                               by current data.: ' - • -

                                                                                 .Dated^JuneM, 1817.
                                                                                           .   EDWABB P. Tuiax.
                                                                                               itant .Administrator
                                                                                ^-rrZ&mir tad Watt Uanoatmmt,,
                                                                                  [i  D00.7T-H8M TOft 7-7-T7:8:4S *
                                          uoisrn, VOL 42, NO. ui—fiioAt, JUIT t. 1*77

                                                         C-4
                                                                               •M

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i. ft
               32042
                      Federal Register / VoL 44. No. 108 / Monday. June 4. 1979 / Notices
               Review under 42 U.S.C. I 719(b) (1977
               Supp.) from an ordtr of the Secretary of
               Energy.
              .   Copies of the petition for review have
               been served on th« Secretary.
               Department of Energy, and all
               partfcipattts i
               the Secretary.
                 Any person desiring to be heard with
               reference to such filing thould on or
               before June 12.1979. file a petition to
              -intervene with the Federal Energy
               Regulatory Commission. **? North
               Capitol Street N-E> Washington. D.C
               20438. in accordance with the
               Cnmmissinn's rules of practice and
               procedure (18 CFR L8). Any person
               wishing to become a party or to
               participate as a  party must file a petition
               to intervene. Such petition moat also be
               served on the parties of record in this
               proceeding and the Secretary of Energy
               through Gaynell C. Methvin. Deputy
               General Counsel for Enforcement and
               Litigation, Department of Energy. 12th
               and Femuyhreaia Ave, N.W,
               Washington. D.C 20461. Copiw of the-
              petition for review are on file with  the
              Commission and are available for public
              inspection at Room 1000.023 North '
              Capitol SUKE, Washington. D.C
              204m
              (Docket NO. mrvaei         .

              Triton 7fr4ai
                                                            •
                                                                                         ENVtRONMENTAL PROTECTION
                                                                                         AGENCY
             detenmnannn the* it haa
                                                                           PoOcyCo
                                                                                                      htgO]
             Area RateOptaiottNo. S9»Corr»tea ft.w.
             <»Heiaed fc« certain sales 
-------
                     Federal Register / VoL 44. No.  108 / Monday. June 4. 1979 / Notices
                                                                                           32043
 chloroform and methylene chloride, do
 not appreciably affect ambient ozone
 levels. Hence. EPA will not disapprove
 any state implementation plan or plan
 revision for iti failure to contain
 regulation* restricting emissions of these

   Although these substances need not
 be controlled under state
 implementation plans for the purpose of
 achieving ambient ozone «*»«"i*>>in*a
                       Ftutectluu Agencjr* 26 FeoenI Plszs«
                       Room 1008. New York, N.Y. 10007.
                       Attention; Coastal Plain Aquifer.
                       Information conCTf^^ff the QyastalE
                       Plain Aquifer System will be available
                       for inspection at the above address.
                                                                                Dated: May ZL 1979.
                                                                              BekanitCBwdc.
                                                                                      Adatinutntof,
                                                                              pv Dec. rt-irat mw M-X M« «•)
                                                                                    ooti IMP «t M
                                                                              [FRL 1239-3 OPP-OOMS]

                                                                              Stete-FIFRA Issues) Research and
                                                                              Evaluation Group (SFIREC); Working
                                                                              Committee on Enforcement; Open
                                                                              AQINCY: Environmental Protection
                                                                              Agency (EPA). .Office of Pesticide
                                                                              ACTiONe Notice of Open Meeting. _

                                                                              SUMMARY: There will be a two-day
                                                                              meeting of the Working Committee on
                                                                              Enforcement of the State-FTFRA Issues
                                                                              Research and Evaluation Croup
                                                                              (SFIREC) on Tuesday and Wednesday,
                                                                              June 5-8. 1979. beginning at 830 a.m.
                                                                              each day, and concluding by 12 noon on
                                                                              June 8th. The meeting will be held at the
                                                                              Atlanta Town House. 100 Tenth Street
                                                                              N.W, Atlanta. Georgia. Telephone: 404/
                                                                              892 aaoq and will be open to the public.
                                                                              KH rUMTMOl INKMMATION CONTACT:
                                                                              Mr. William Buffalpe. North Carolina
                                                                              Department of Agriculture. Raleigh.
                                                                              North Carolina. Telephone: 919/733-
                                                                              3558: or Mr. Anthony Dellaveccnia.
                                                                              Pesticide ""^ Toxic Substances
                                                                              Enforcement Division, EPA. 401 M
                                                                              Street S.W, Washington, D.C,
                                                                              telephone! 202/755-0014.
                                                                              •UMtfJHMTAirf mpomiATiON; This the
                                                                              second meeting of the Working
                                                                              fnmmiHmm gg Enforcement The meeting
                                                                              will be otucerued with the following
                                                                                1. Plan for future recall and
                                                                               uspension orders:
                                                             Section 28 and 27 of FIFRA:
                                                               3L Status of State-primacy use
— 4*Use of recommendations of

-pesticide sales representatives;
  . 5. Discussion of definition of "non
 uu|i lend;1*     ° * •
   8. FIFRA Section 7— producers of
 active ingredients; end
   7. Other enforcement matters which
 may arise.
   Dated: May 29.1970,
                                                                             Dfputf Aniitant Adminutmtor for Pesticide
                                                                                OM. i+xrm ntt M-m MI «^
                                                        C-6

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                                 T^faj&ftii«. iffiiritu&tt^, NotiCM
:-. i •
      lachicMwithmtfaedefiniUoaof >
    »ontargetsitaa an areas of permanent-
    human habitation inchiding permanent
    residences, schools, churches, and anaa
    u which substantial conmarcial     -.
    activities an condacied (*g_ aaoppfai
    centers), domestic apiaries, and "':
    pghllftyJ«.<««.<«^ BM^. ftj arf.flflp,^ .
    aquatic habiiats such as critical  -'
    Aeries, municipal water supply "-
    intakes aad other waters (which include
    rivers, stnams. ponds, lakes,  and    .  '.
    ephemeral streams and ponds with  .
    flowing or standing water visible from
    aa aircraft flying at an altitude of 1.000
    feet above the terrain at the time of
    treatment), are included within the
   definition of a sensitive ana. The
   »»•»« of «ny pesticide spray it not
   permitted over a sensitive ana or in the
   surrounding buffer zone. Buffer zones
   are,defined aa anas intended  to receive
   only spray drift fallout from the
   application sites.
    The Agency recognizes diet  some
   seasonal dwellings, such as hunting and
   fishing camps, may be located  inor
   adjacent to the treatment ana. These
   dwellings an not considered to be
 - permanent residences and thus will not
   be buffered against direct application.
  However, many of these dwellings an
  "•"•qMMc sites listed in Table n
  which will be buffered.
    To minimize operational errors.
  overflights of the treatment area prior to
  the actual spray operation an
  •nconraged. The purpose of these
  overflights is to locate visually all
  sensitive anas and buffer zones
  designated on the spray block maps.
  Particular attention should be given to
  identifying ephemeral stream* and
  ponds visible from an aircraft flying at
  an altitude of looo feet or less above the
  terrain at the time of treatment  which
  may not be designated on the spray
  block, map due to  their seaaonality.
                                                 consistent with tat purposes of thia
                                                 Act,"  . •.-,.-jt"- r-'.-: .„"' f.—"
                                                   Dated: May hUMi.'.  .
                                                 »le
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  1. REPORT NO.
    EPA-450/3-82-QQlh
  |«. TITLE AND SUBTITLE	

   fenufectZHM Pr°cefS6S 12 synthe«c Organic Chemical
   Standards      " Background Information for Final
  • ""F.0"M'NO ORO'*NIZAT'0»' WAMl AND ADDRESS
   Office of Air  Quality Planning and Standards
   L!' ST?™6?*31  Protection Agency
   Research  Triangle  Park,  North Carolina  27711
    wiiu **uanuar U5
   Office of Air and Radiation, U.  S.  EPA
   Research Triangle Park. North Carolina  27711
                                                         'fort campittint)	

                                                                iTRECIPIENT-S ACCESSION NO.
                                                                  IEPOBT DATE
                                                                   June 1990

                                                                >. i-cnroiiMINO ORGANIZATION COoT


                                                                . rsBPORMING ORGANIZATION REPORT NO.
                                                                 68-02-3058

                                                             13. TYPE OP REPORT AND PERIOD COVEREo"
                                                               EPA/200/04
                                                              .nt.n»tio, use  by
                                                ^^
   -u            rape
   industry are being pramjlaated under  Section
           on
                  proposed
                                                            ?r9a"'J.<:hen1cal manufacturing
                           .
                 DESCRIPTORS
Air  pollution
Air  oxidation processes
Pollution  control
Standards  of performance
Organic chemical  industry
volatile organic compounds (VOC)
              angle Park. N. C.  2771l
SPA Form 22JO-1 111-.
            (R... 4-77)   Mlv,0oi CD,TION „ OMOl.eTE
                                 KEY WORDS AND DOCUMENT ANALYSIS
                                               r.^T.,,EHS/OPENBNOtiDTEHMS .   c^,——-
                                                Air Pollution Control
'». ikCUH.TY CLAM OlntKw,,,
   Unclassified     f

   Unclassified
                                                                         '. IVO. OF PAGE

                                                                          81
                                                                       TZ2. PRICE '

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